ML20213C659
| ML20213C659 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/29/2020 |
| From: | Anderson V Nuclear Energy Institute |
| To: | Borges J Office of Administration |
| References | |
| 85FR39599 00002, DG-1285, DG-1286, DG-1287, DG-1288, NRC-2012-0110 | |
| Download: ML20213C659 (6) | |
Text
PUBLIC SUBMISSION As of: 7/29/20 2:22 PM Received: July 29, 2020 Status: Pending_Post Tracking No. 1k4-9i34-kydx Comments Due: July 31, 2020 Submission Type: Web Docket: NRC-2012-0110 Issuance and Availability; request for comment (DG-1285, DG-1286, DG-1287, DG-1288)
Comment On: NRC-2012-0110-0022 Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities Document: NRC-2012-0110-DRAFT-0019 Comment on FR Doc # 2020-14197 Submitter Information Name: Victoria Anderson Address:
1201 F St., NW Ste 1100 Washington, DC, 20004 Email: vka@nei.org General Comment Industry Comments on Draft Regulatory Guide (DG) 1362, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities," 85 FRN 39599-39600; Docket ID NRC-2012-0110 Attachments 07-29-20_NEI Industry Comments on (DG) 1362, 85 FRN 39599-39600; Docket ID NRC-2012-0110 with attach Page 1 of 1 07/29/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064847b59ac&format=xml&showorig=false SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Harriet Karagiannis, Stanley Gardocki Comment (2)
Publication Date:
7/1/2020 CITATION 85 FR 39599
VICTORIA K. ANDERSON Technical Advisor, Engineering & Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8101 vka@nei.org nei.org July 29, 2020 Jennifer Borges Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Comments on Draft Regulatory Guide (DG) 1362, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, 85 FRN 39599-39600; Docket ID NRC-2012-0110 Project Number: 689
Dear Ms. Borges:
The Nuclear Energy Institute (NEI)1, on behalf of its members, submits the following comments on DG-1362, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities (Regulatory Guide (RG) 1.200, Revision 3). We are supportive of the effort to revise this RG to improve the clarity of NRCs expectations regarding Probabilistic Risk Assessment (PRA) technical acceptability for risk-informed licensing applications, and appreciate the opportunity to comment on the draft revision.
In general, the draft revised RG offers improved clarity for licensees, and NEI appreciates the NRCs dedication to continuous improvement in this area. However, some of the changes do not offer a clear benefit to risk-informed regulatory activities. Specifically, this draft revision has a new appendix on Other Hazards (Appendix D), which is both duplicative and in conflict with the ASME/ANS PRA Standard endorsed by RG 1.200. NEI suggests deleting this appendix, as its inclusion reduces regulatory clarity. Additional detailed comments are attached to this letter.
In addition to the above and enclosed comments, the Federal Register Notice solicited comments on whether or not licensees should periodically close all of their PRA peer review findings to ensure confidence in the information used in risk-informed programs. NEI and its members do not support such an addition to RG 1.200, as the configuration control criteria in NEI 17-07, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard, PWROG 19027-NP, Newly Developed Method Requirements and Peer Review, and the ASME/ANS PRA Standard itself, all of which are endorsed in DG-1362, are sufficient to ensure fidelity of information used in risk-informed applications. The configuration control, or maintenance and upgrade, processes are included as part of the PRA peer review, and NRC has access to documentation of these reviews as part of their review of License Amendment Requests. No additional language is needed 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Ms. Jennifer Borges July 29, 2020 Page 2 in DG-1362 relative to configuration control to provide such assurance. It is unclear if there has ever been a regulatory concern that would be addressed by such a requirement; if such examples exist, NEI would welcome a dialogue with NRC and other stakeholders to discuss the specific occurrences and determine the best means to address them.
Finally, NEI understands that NRC does not intend to sunset Revision 2 of RG 1.200 with issuance of Revision 3. This is important to licensees, as many have conducted PRA technical acceptability evaluations for ongoing and upcoming risk-informed licensing applications using Revision 2, and there is little value in repeating these evaluations given that the same standard is endorsed in both revisions. A clear statement from NRC on the retention of RG 1.200 Revision 2 is important to the operating fleet to support continued use of risk-informed licensing processes.
We encourage NRC to consider all stakeholder comments prior to finalizing the revision to this RG. Please contact me at vka@nei.org or (202) 739-8101 with any questions or comments about the content of this letter or the attached comments.
Sincerely, Victoria K. Anderson c:
Mr. Michael Franovich, NRR Mr. Michael Cheok, RES Mr. Robert Pascarelli, NRR Mr. Anders Gilbertson, RES Ms. Harriet Karagiannis, RES
Attachment:
NEI Detailed Comments on DG-1362, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities Section Comment Proposed Resolution General RG 1.200 is applicable to risk-informed licensing applications. However, this draft revision does not distinguish between risk-informed licensing applications and other risk-informed activities. This is an important distinction, as risk-informed activities constitute a much larger scope than licensing applications. It is not necessary to conduct large-scale PRA technical acceptability reviews for all of these activities, particularly for those that use risk information without strong reliance on specific numerical results.
Change application to licensing application throughout the document as appropriate General While NEI issued NEI 17-07 to follow on from NEI 05-04, NEI 07-12, and NEI 12-13, these three documents should remain an accepted NRC approach for conducting peer reviews. Retaining (not sunsetting) RG 1.200, Rev. 2 would accomplish this, and would support licensees who have conducted peer reviews in the decades since Rev. 2 was issued.
In issuance of RG 1.200, Rev.
3, specify that Rev. 2 is still an acceptable approach to the NRC Section 2.2.1, Page 42.
In table 17, as-to-be-built, as-to-be-operated is too narrow in scope, and should be adjusted to recognize that this status can apply to operating reactors with planned modifications.
Remove the in the case of a DC or COL application qualifier of as-to-be-built, and as-to-be-operated Section 2.2.1, Page 42 Table 17 should reflect that walkdowns are not needed for all peer reviews Add as appropriate after Performs independent walkdowns of the plant to confirm PRA inputs Section 2.1, Page 40 It is not fully accurate that All supporting requirements related to NDMs are applicable for peer review of NDMs. Depending on the scope of the method, some of the NDM SRs may not be applicable.
Replace with All supporting requirements related to NDMs should be evaluated during peer review of NDMs.
Section 2.2.2, Page 43 This section states, A peer review is performed on a PRA upgrade, which includes the use of an NDM in a PRA.
However, this is not strictly true, as the driver for PRA peer reviews of an upgrade is the use of such an upgrade in a risk-informed licensing application.
Replace the statement with Prior to use in a licensing application, a peer review should be performed on a PRA upgrade, including the use of an NDM in a PRA.
Section 2.2.3, Page 44 This section includes a clarification to NEI 17-07, which states that, Documentation of Remove this clarification
the resolution of a peer review finding should describe how the deficiency in the finding was addressed such that it can be easily demonstrated that the associated supporting requirement is met. However, this expectation is already defined in NEI 17-07 on page E-4, where it is stated that the assessment report should include A summary of the review teams decisions for each finding within the scope of the review, along with the rationale for determination of adequacy or inadequacy for closure of each finding in relation to the affected portions of the associated SR. If multiple SRs are referenced by a single finding, the affected portions of all associated SRs should be addressed.
Section 2.2.4, Page 45 Paragraph 2 of this section states, "Differences between the current version of ASME/ANS RA-Sa-2009, as endorsed by the NRC, and the earlier version (ASME RA-Sb-2005) should be identified and addressed by the licensee in a risk-informed application."
This statement needs clarification. As it is currently worded, it prescribes the need to assess differences between the current endorsed version of the PRA Standard (i.e.,
ASME/ANS RA-Sa-2009) and the earlier version (i.e., ASME RA-Sb-2005). The sentence should be updated to specify that this is a requirement when providing a submittal based on the earlier version of the standard.
Replace the sentence with "When relying upon an earlier version of the standard (e.g.,
ASME RA-Sb-2005),
differences between the current version of ASME/ANS RA-Sa-2009, as endorsed by the NRC, should be identified and addressed by the licensee in a risk-informed application."
Section 3.3, Page 48 The second paragraph should be revised to allow for peer review of scheduled plant modifications.
After (1) the PRA model, or those portions of the model required to support the application, represents the as-designed or as-built and as-operated plant, add or as-to-be-built, as-to-be-operated plant to reflect the potential for review of scheduled modifications.
Glossary, Page 54 The definition of as-designed, as-to-be-built, as-to-be-operated should be expanded to allow for peer review of a plant configuration including scheduled modifications Add or the PRA used to model the plant configuration that reflects future scheduled modifications to the end of the definition
Glossary, Page 55 The definition of PRA acceptability should be revised to reflect the context of PRA acceptability for a specific regulatory decision.
Revise the definition to read The ability of a PRA to support a specific risk-informed regulatory decision.
Appendix D The purpose of Appendix D is unclear, particularly given that RG 1.200 endorses the screening part of the ASME/ANS PRA standard, and addresses other hazards in regulatory position C.1.2.9. The Appendix specifically states that Table D-1 provides an extensive list and general description of the hazard groups and the hazards within those groups that should be considered during the development of a base PRA.
There is no context for what should be considered means beyond the screening endorsed in the ASME/ANS PRA Standard.
Remove Appendix D from the document.