ML22272A554
| ML22272A554 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/07/2022 |
| From: | Michelle Honcharik NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Honcharik M, 301-415-1774 | |
| References | |
| EPID L-2022-PMP-0003 | |
| Download: ML22272A554 (7) | |
Text
October 11, 2022 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RE: TRAVELER TSTF-591, REVISE RISK INFORMED COMPLETION TIME (RICT) PROGRAM (EPID L-2022-PMP-0003)
Dear Members of the Technical Specifications Task Force:
By letter dated March 22, 2022 (Agencywide Documents Access and Management System Accession Nos. ML22081A224) you submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to incorporate Traveler TSTF-591, Revise Risk Informed Completion Time (RICT) Program, into the standard technical specifications.
Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. Mr. Brian Mann, Vice President of Industry Programs, EXCEL Services Corporation, agreed that the NRC staff will receive your response to the enclosed request for additional information questions within 60 calendar days of the date of this letter.
The review schedule that was provided in the acceptance letter dated June 30, 2022 (ADAMS ML22181A744), has changed.
MILESTONE ORIGINAL DATE NEW DATE Issue Draft Safety Evaluation January 6, 2023 February 6, 2023 Issue Final Safety Evaluation March 22, 2023 June 22, 2023 If you have any questions, please contact me at (301) 415-1774 or via email to Michelle.Honcharik@nrc.gov.
Sincerely, Digitally signed by Michelle C. Michelle C. Honcharik Date: 2022.10.11 Honcharik 15:15:20 -04'00' Michelle C. Honcharik, Senior Project Manager Technical Specification Branch Division of Safety Systems Office of Nuclear Reactor Regulation
Technical Specifications Task Force Project 753
Enclosure:
Request for Additional Information cc: See next page
Technical Specifications Task Force Project 753 cc:
Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann Email: brian.mann@excelservices.com Drew Richards STP Nuclear Operating Company 12090 FM 521 Mail Code: N5016 Wadsworth, TX 77483 Email: amrichards@stpegs.com Kevin Lueshen Constellation Energy Generation 4300 Winfield Road Warrenville IL 60555 Email: kevin.lueshen@constellation.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Ryan M. Joyce Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-274-EC Birmingham, AL 35243 Email: rmjoyce@southernco.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 Email: wasparkm@southernco.com
ML22272A554 NRR-106 OFFICE NRR/DSS/STSB NRR/DRA/APLA NRR/DSS/STSB NRR/DSS/STSB MHoncharik (GEMiller NAME RPascarelli VCusumano MHoncharik for)
DATE 09/28/2022 10/4/2022 9/29/2022 10/7/2022 Enclosure REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATIONS TASK FORCE TSTF-591 REVISE RISK INFORMED COMPLETION TIME (RICT) PROGRAM (EPID L-2022-PMP-0003)
By letter dated March 22, 2022 (ADAMS ML22081A224) you submitted a request to the U.S. NRC to incorporate Traveler TSTF-591, Revise Risk Informed Completion Time (RICT)
Program, into the standard technical specifications. Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review.
APLA RAI 1 Section 3.3 of the traveler provides a bulleted list of the contents that the proposed report must include. Bullet 3 specifically discusses that the report should include open facts and observations (F&Os) from the peer-review of the implementation of the newly developed methods (NDM). Throughout Section 3.1 of the traveler, specifically the second to last paragraph, the traveler does not discern between open technical-F&Os, or open implementation-F&Os resulting from an NDM peer review. Furthermore, Section 3.1 of the traveler states in part a quote from RG 1.200 Regulatory Position C.2.2.2.2:
If open finding-level F&Os from an NDM peer review cannot be successfully closed via an NRC-endorsed peer review process, the NDM could be submitted to the NRC to determine the acceptability of the NDM. Submitted applications that use NDMs with open finding-level F&Os related to the NDM will be subject to review by the NRC to determine acceptability of the NDM, its implementation in the PRA [probabilistic risk assessment], and its potential impact on the application.
The above paragraph from the traveler discusses the submission of applications for NRC staff review of NDMs for acceptability where open finding-level F&Os cannot be closed via an NRC-endorsed peer review process. It is unclear to the NRC staff what specific application processes the traveler is referring to (e.g., Topical Report), or whether it proposes submission via the proposed NDM report. Furthermore, as observed in APLA RAI below, dependent upon the time frame that is stipulated for the report, the NRC further observes the need for a specified time frame due to a potential gap in the receipt of applications submitted to the NRC staff for determination of NDM acceptability in the RICT program prior to use in a RICT calculation.
Please provide the following information:
- a. Confirm for the report that is being proposed to be submitted to the NRC for NDM use in the RICT program will only be used to submit NDMs with, all the open F&Os resulting from the technical review of the NDM closed using an NRC-endorsed peer-review process.
- b. From Section 3.1 of the traveler, identify which submittal process the traveler is proposing for a licensee to submit NDMs where open finding-level F&Os from an NDM peer review cannot be successfully closed using an NRC-endorsed peer review process.
Enclosure In addition, confirm the type of open finding-level F&Os (i.e., technical or implementation).
- c. In response to APLA RAI 1.b above, and congruent to response provided in APLA RAI 2, describe how it is ensured that an NDM submitted for NRC staff review will not be used in the RICT program before an NRC staff determination of acceptability for that NDM has been concluded. If the intent is for these NDMs to also be submitted via the traveler proposed report, the NRC notes, that the proposed reporting requirement only requires the NDM to be submitted. Therefore, it is unclear if the licensee intends to submit an NDM prematurely before the appropriate NRC staff determination of acceptability has been concluded. In the discussion include confirmation that NDMs where open F&Os could not be closed using an NRC-endorsed peer review process, the NDM will not be used in the RICT program before the NRC staff determination of acceptability has been concluded.
- d. From the observations provided throughout APLA RAI 1.a-c above, for technical specification (TS) 5.5 paragraph g, propose additional language that ensures no ambiguity, such as interpreting open F&O resulting from the technical peer review of the NDM only impact documentation, etc. This language should be clear and include explicit direction to the PWROG-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review (ADAMS ML20213C660), as endorsed by Regulatory Guide (RG) 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities (ADAMS ML20238B871).
APLA RAI 2 In Appendix A of the traveler, within the column titled Discussion for TS 5.6.X paragraph g, on page A-5, states in part:
A newly developed method" that has been previously submitted by a licensee no longer satisfies the definition of a "newly developed method" and a report is not required.
In the glossary of RG 1.200, Revision 3, the definition of newly developed method and consensus method are described as follows:
Consensus method/model: In the context of risk-informed regulatory decisions, a method or model approach that the NRC has used or accepted for the specific risk-informed application for which it is proposed. A consensus method or model may also have a publicly available, published basis and may have been peer reviewed and widely adopted by an appropriate stakeholder group.
Newly developed method: A PRA method that has either been developed separately from a state-of-practice method or is one that involves a fundamental change to a state-of-practice method.
An NDM is not a state-of practice or a consensus method.
The NRC staff does not interpret an NDM submitted by a licensee under the proposed TS reporting requirement, to no longer meet the definition of an NDM for use in the RICT
Enclosure program by another licensee. For the submittal of the RICT program TS report, the report is submitted to the docket number for that specific facility operating license (FOL) RICT program and is not considered generically applicable to other RICT programs. Furthermore, the NDM submitted via the TS report would not satisfy the definition of a consensus method because the acceptance of that NDM is not for a specified risk-informed application generically, but is accepted for use in the RICT program for that specific docket(s). The NRC staff is not aware of any publicly available or published basis that concludes the generic use of the accepted NDM for the specified risk-informed application. Therefore, it is unclear to the NRC staff how an NDM that has been previously submitted by one licensee no longer satisfies the definition of an NDM and would not be required to be submitted by another licensee to be used in their RICT program. In that context, address the following:
- a. For an NDM report submitted to the NRC staff in accordance with the proposed TS reporting requirement, explain how that NDM meets the definition to be considered a consensus method, as defined in the glossary of RG 1.200, Revision 3. The explanation should include:
- 1. Identify the publicly available, or published basis where the NRC staff has determined that the NDM is accepted for use in the TS program (i.e.,
generic to the TS program and not specific to a licensees TS program)
AND
- 2. Why the use of an NDM that has not been submitted by a licensee in a TS report for that specific FOL docket, for that licensees RICT program is appropriate?
The NRC staff acknowledges that the regulatory position C.2.2.2.2 in RG 1.200, Revision 3, recognizes that Section 5.2 of PWROG-19027-NP states that the peer review report for an NDM must be publicly available.