ML20133J970

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NRR E-mail Capture - Slides for May 15, 2020, Public Meeting to Discuss NRC Tech Spec Changes to Technical Specifications Task Force (TSTF)-505 That Would Allow Licensee Control of Newly Developed PRA Methods in Accordance with RG 1.200
ML20133J970
Person / Time
Issue date: 05/12/2020
From: Ed Miller
NRC/NRR/DORL/LPL2-1
To: Ed Miller
NRC/NRR/DORL/LPL2-1
References
Download: ML20133J970 (12)


Text

From:

Miller, Ed Sent:

Tuesday, May 12, 2020 7:57 AM To:

Miller, Ed

Subject:

Slides for May 15, 2020, Public Meeting Attachments:

May 15 2020 Public Meeting Slides.pdf Attached are the slides for the May 15, 2020, public meeting on the TSTF-505 License Condition.

Hearing Identifier:

NRR_DRMA Email Number:

580 Mail Envelope Properties (MN2PR09MB5963CD2B3FAF7D985CF60D13E9BE0)

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Slides for May 15, 2020, Public Meeting Sent Date:

5/12/2020 7:56:58 AM Received Date:

5/12/2020 7:57:00 AM From:

Miller, Ed Created By:

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"Miller, Ed" <Ed.Miller@nrc.gov>

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MN2PR09MB5963.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 99 5/12/2020 7:57:00 AM May 15 2020 Public Meeting Slides.pdf 1485438 Options Priority:

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Newly Developed Methods and Planned Update to RG 1.200: Status Update Sunil Weerakkody, Senior Level Advisor, Probabilistic Risk Assessment, Office of Nuclear Reactor Regulation Division of Risk Assessment May 15, 2020

OVERVIEW

  • Update status of the four tasks relating to dispositioning PRA Newly Developed Methods (NDM issue).

- Inspection procedures (information)

- Office Instruction (information)

- Technical specification (discussion)

- Update to RG 1.200 (discussion) 5/15/20: Public Telecon on Newly Developed Methods 2

5/12/2020

Updates to Inspection Procedures to Address Needs of Risk-Informed Initiatives

  • IP 71111.13, MAINTENANCE RISK ASSESSMENTS AND EMERGENT WORK CONTROL, has been updated to address needs of Tech Spec 4b, Effective January 1, 2020.
  • IP 71111.22, SURVEILLANCE TESTING, has been updated to address periodic verification needs of 10 CFR 50.69 and Risk Initiative 5b, Effective January 1, 2020.
  • IP 71111.12, MAINTENANCE EFFECTIVENESS, has been updated to address periodic verification needs of 10 CFR 50.69, Effective January 1, 2020.

3 5/15/20: Public Telecon on Newly Developed Methods 5/12/2020

Updates to Inspection Procedures to Address Needs of Risk-Informed Initiatives (Cont.)

  • IP 71111.18, PLANT MODIFICATIONS, has been updated to address periodic verification needs of Tech Spec Risk Initiatives 4b, 5b and 10 CFR 50.69, Effective January 1, 2020.
  • NRR staff are evaluating revising periodic inspections to consider inspecting the maintenance of PRA acceptability to ensure it is maintained in accordance with the approved license and regulatory requirements.

5/15/20: Public Telecon on Newly Developed Methods 4

5/12/2020

Preliminary Views For Information:

Development of the NRR Office Instruction Addresses the need for inter-division and inter-office coordination in response to NEI proposed alternative to TSTF-505 Administrative Technical Specification.

Key attributes Will rely on revised inspection procedures.

Include elements to encourage licensees to use NDMs that have received an opportunity for regulatory review.

Explore the possibility to emulate the process used by NRC staff to review steam generator inspection report.

Will inform NDM submitter about the staff review without approving or disapproving method.

Fee billing will use current NRC processes.

5 5/15/20: Public Telecon on Newly Developed Methods 5/12/2020

Proposed Alternative to Tech Spec.

  • Incorporated comments provided during public tele-con on March 11, 2020.
  • Industry Comments were incorporated after discussions with NRR\\DSS Technical Specification, NRR\\DRA licensing and operational support branch staff and branch chiefs.
  • Does not provide a formal NRC position.
  • Formal position will be established via RG 1.200 update.

6 5/15/20: Public Telecon on Newly Developed Methods 5/12/2020

Preliminary for discussion (Not a formal staff position)

[5.5.15/5.5.18], RISK-INFORMED COMPLETION TIME PROGRAM e.

A RICT must be calculated using [list specific approaches used (e.g., internal events PRA, fire PRA, addition of bounding seismic risk to RICT calculations, etc.)]. Probabilistic risk assessment (PRA) model used to calculate a RICT shall be developed, maintained, and upgraded in accordance with processes described in Regulatory Positions C.1, C.2, C.3, and C.4 in Regulatory Guide (RG) 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities.

f.

Use of any newly developed methods, as defined in RG 1.200, Revision 3, requires satisfying all applicable review requirements in Tables 1-7.2-2 through 1-7.2-7 of Pressurized-Water Reactor Owners Group-19027-NP, Revision 1, Newly Developed Method Requirements and Peer Review, Revision 0, in accordance with the process in NEI 17-07, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard, Revision 2.

{assumes staff endorses PWROG-19027-NP & NEI-17-07 without w/o exceptions}

g.

A report, describing the implementation of a newly developed method, shall be submitted in accordance with Section 5.6.8, following a PRA upgrade that uses a newly developed method and prior to using that method in the RICT program.

5/15/20: Public Telecon on Newly Developed Methods 7

5/12/2020

Preliminary for Discussion (not a formal NRC position) 5.6.8, Newly Developed Method PRA Upgrade Report A report describing the implementation of a newly developed method shall be submitted following a PRA upgrade that uses a newly developed method and prior to using that method to calculate a RICT in accordance with Specification [5.5.15/5.5.18]. A PRA upgrade report on a newly developed method implementation is not required to be submitted if the implementation of newly developed method has been previously reported to the U.S. Nuclear Regulatory Commission for a RICT program.

The report shall describe the scope of the upgrade and shall include:

a. The PRA models upgraded, and the newly developed method used;
b. A description of the acceptability of the newly developed method consistent with Section 9.1 of NEI 17-07, "Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard," Revision 2;
c. The peer review and finding closure reports for the newly developed method available to the NRC for oversight and inspection activities;
d. All open findings from the peer review of implementation of the newly developed method and how those findings were resolved or demonstrated not to have a significant impact on the PRA; and
e. All changes to key assumptions related to the newly developed method or its implementation.

5/15/20: Public Telecon on Newly Developed Methods 8

5/12/2020

RG 1.200 Status Update

  • Incorporated changes to address NRR and RES management comments.
  • Some delays due to large number of time critical COVID-19 licensing amendment and exemption reviews (ACRS meeting postponed).

5/15/20: Public Telecon on Newly Developed Methods 9

5/12/2020

Path forward

  • Proposed revisions to NEI 17-07 based on public comments.
  • Proposed revisions to address needs of Advanced LWRs.
  • Maintaining acceptable high-quality models after Licensing Phase (e.g., what are industry plans to close peer review F&Os that are not associated with NDMs).

5/15/20: Public Telecon on Newly Developed Methods 10 5/12/2020