ML22070B121

From kanterella
Jump to navigation Jump to search
Industry Perspective on IEEE Std -1819
ML22070B121
Person / Time
Site: Nuclear Energy Institute
Issue date: 03/16/2022
From: Anderson V
Nuclear Energy Institute
To:
Office of Nuclear Regulatory Research
Ray, S; Roche-Rivera, R
Shared Package
ML22070B114 List:
References
Download: ML22070B121 (10)
v • d • e


Text

Click to edit Master title style Industry Perspective on IEEE-1819 BWROG, PWROG, NEI NRC Public Meeting March 16, 2022 1

Click to edit Master title style Overview

  • Industry concern with potential NRC endorsement of IEEE-1819
  • Path forward 2 2

Click toofedit Scope Industry Master Evaluation title styleof IEEE-1819

  • NEI, BWROG, and PWROG conducted comprehensive survey
  • All currently operating reactors
  • ALWR, SMR, and ANLWR vendors
  • Future operators
  • No currently operating reactor, reactor vendor, or future operator indicated any intent to use IEEE-1819
  • NRC endorsement would be detrimental to predictable and stable regulatory environment
  • Reduces clarity in 50.69 implementation
  • Unnecessarily uses NRC staff resources with no end users 3 3

Click to edit Industry Concerns MasterwithtitleEndorsement style of IEEE-1819

  • Ineffective use of NRC resources
  • Staff time devoted to endorsement of standard with no end users
  • Complication of training inspection teams on inapplicability of endorsed standard at sites
  • IEEE-1819 does not contain anything specific to electrical components
  • Would result in NRC endorsement of two incompatible categorization processes
  • PRA sensitivity differences could lead to conflicting outcomes 4 4

Click to edit IEEE-1819 and Master NEI 00-04 title style Differences IEEE-1819 NEI 00-04 Comments 5.2.3.a Supplementary analyses that No Requirements The non-PRA portions of NEI 00-04, are used to compensate for PRA including the IDP, adequately address the limitations in quantifying the risk limitations of a quantitative PRA during plant shutdown and the risk of hazards such as fire risks, seismic risks, and other external risks (tornadoes, external floods, etc.)

5.2.3.b Deterministically derived risk No Requirements The non-PRA portions of NEI 00-04, assessments that consider, like the including the IDP, adequately address the PRA, the impact and likelihood of limitations of a quantitative PRA failure of the EESC under consideration 5.2.3.c Plant design bases No Requirements The non-PRA portions of NEI 00-04, including the IDP, adequately address the limitations of a quantitative PRA 5 5

Click to edit IEEE-1819 and MasterNEI 00-04title styleDifferences IEEE-1819 NEI 00-04 Comments 5.2.3.d Maintenance of defense-in- Section 6 Defense in Depth Assessment Fully covered by Section 6 and IDP depth Review 5.2.3.e Maintenance of sufficient safety General Considerations Fully covered by IDP Review margins 5.2.3.f Plant and industry operating Section 9 IDP Review Fully covered by IDP Review experience 5.2.3.g Operational and maintenance No Requirements The non-PRA portions of NEI 00-04, processes including the IDP, adequately address the limitations of a quantitative PRA 5.3.3.5 Increasing the failure rate of 8. Increase failure rate of all RISC-3 Increasing the failure rate of RISC-4 LSS EESCs simultaneously by a SSCs SSCs is inappropriate as there are common multiplier changes to the requirements for RISC-4 SSCs 6 6

Click to edit IEEE-1819 and Master NEI 00-04 title style Differences IEEE-1819 NEI 00-04 Comments 5.3.3.5 Removal of credit for all Table 2 - Set HEPs to 95th and 5th Complete removal of HEPs for LSS operator recovery actions associated percentile equipment is inappropriate as the with LSS EESCs operator actions should not be impacted by alternate treatment. Exploring the impact of the range of realistic HEPs as identified in NEI 00-04 provides assurance that reliability of equipment is not be masked by undo reliance on operator actions 5.3.3.5 Increasing the common cause Table 2 - Change CCF events to 95th & Limiting the sensitivity study to LSS failure contributions of the LSS EESCs 5th percentiles components is non-conservative and by a common multiplier addressed by the importance measures used to determine potential LSS/HSS components 5.3.3.5 Increasing the planned Table 2 - Set all maintenance terms to 0.0 maintenance unavailability by an appropriate multiplier 7 7

Click to edit IEEE-1819 and Master NEI 00-04 title style Differences IEEE-1819 NEI 00-04 Comments 5.3.4.1 a) List all components in the system. Remove from the list No Requirement Could be one way to any identified components that are considered spared, abandoned, document, but shouldnt be or simply represent an empty space in a cubicle. perceived as a requirement b) Sort the scoped components by type and current flow order. For example, identify a particular component as a bus that receives power from a supply circuit breaker and distributes power to various loads through individual load circuit breakers. The supply circuit breaker would be listed first, then the bus, and finally the load circuit breakers, with all of these components grouped under the bus name.

c) Identify each end load that is powered from this system. Obtain the relevant end load information, such as identification number, description, and risk data, where available. End loads may be powered directly from a load breaker, or from a distribution panel that is fed by a load breaker, or from a relay panel that is fed from a distribution panel that is itself fed from a load breaker 8 8

Click to edit IEEE-1819 and Master NEI 00-04 title style Differences IEEE-1819 NEI 00-04 Comments 5.3.4.5.2 Busbars may be categorized as LSS even if Not Applicable NEI 00-04 does not allow for categorization SSCs as there are HSS loads powered from that bus, because of LSS because they are inherently reliability the passive and inherently reliable nature of a busbar, as demonstrated by facility-specific operating experience. Cables shall be categorized the same as the equipment they support. Transformers shall be categorized as HSS if they are the only source of power for one or more downstream electrical component(s) that are classified as HSS.

6 Alternate Treatment Requirements No Applicable 50.69 does not require NRC approval or endorsement of alternate treatment requirements. Each utility may use the information related to alternat treatment in IEEE-1819 if it meets there needs, but endorsement would imply utilities should use this guidance Annex B No Completing this information for each SSC is Requirement cumbersome with no commensurate value. To our knowledge, it has not been piloted to determine the level of effort or how the results would vary from the endorsed NEI 00-04 process 9 9

Click Forward Path to edit Master title style

  • Industry strongly recommends cessation of activities related to NRC endorsement of IEEE-1819 consistent with multiple letters
  • NEI, October 6, 2021
Retrieved from "https://kanterella.com/w/index.php?title=ML22070B121&oldid=3434863"