ML23315A000

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Pcc Status - ROP Public Meeting - 16 NOV 23 (003)
ML23315A000
Person / Time
Issue date: 11/10/2023
From: Lundy Pressley
NRC/NRR/DRA/APOB
To:
References
Download: ML23315A000 (17)


Text

ROP Bi-Monthly Public Meeting x

Enhancing Oversight of PRA Configuration Control x

November 16, 2023 Lundy Pressley Reliability and Risk Analyst Office of Nuclear Reactor Regulation Division of Risk Assessment PRA Oversight Branch

2 Agenda

3 Conduct public meeting Workshop with Tabletop sites/Industry Stakeholders Mar 2023 Developed Working Group recommendations for near-term path forward Feb/Jun 2023 Obtained Alignment with NRC Mgt. on PCC Proposal Mar 2023 PCC Project Milestones Develop near-term oversight guidance (OpESS)

Fall 2023 Develop Enf./SDP strategy and Regional Panel Guidance Dec 2023 Issue Public and Recommendations Reports on Tabletops Jun 2023 Begin OpESS 2nd Quarter2024 Develop long-term oversight process 2026 for 2027 Gather feedback on proposal from Industry Winter 2023-2024 Training for OpESS and SDP 1st Quarter 2024

4 Key Messages Operating Experience Smart Sample (OpESS) provides maximum flexibility for regional implementation.

Cross-regional review panel process will ensure consistent application across the Regional Offices.

The OpESS is still DRAFT however it is nearing completion.

OpESS is intended to be resource neutral and is part of the overall graded and balanced approach that will eventually determine the long-term recommendations for PRA Configuration Control (PCC),

which is targeted for implementation in the 2027 ROP inspection cycle.

4

5 What is OpESS?

OpE - Operating Experience and SS - Smart Sample = OpESS The OpESS is designed as an additional tool to be used by agency staff in ROP baseline inspection preparation.

The information and trends identified from OpESS inspections may provide further indication that a specific issue warrants additional agency action.

Each OpESS has a unique and sequential identifier.

https://www.nrc.gov/reactors/operating/ops-experience/operating-experience-smart-sample.html 5

6 What will the OpESS look like?

Balanced approach will ensure that inspectors only review aspects from approved and implemented risk-informed initiatives.

Performance-based in that sampling will be reviewed and adjusted annually until issuance of final recommendations.

x

  • Not all sites would get sampled each year with the OpESS, intent is to use as warranted.
  • WG will provide inspectors with guidance (insights/specifics) on appropriate use/utilization of the OpESS.

OpESS SFCP NFPA 805 RICT 50.69

7 Applicable OpESS Inspections PRIMARY Inspection Procedures:

71111.21M, Comprehensive Engineering Team Inspection, (CETI) 71111.21N.05, Fire Protection Team Inspection (FTPI) 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment SSC Resident Baseline: 71111 71111.06, Flood Protection Measures, 71111.13, Maintenance Risk Assessments and Emergent Work Control 71111.18, Plant Modifications (Primary) 71111.24, Testing and Maintenance of Equipment Important to Risk.

71151, Performance Indicator Verification 71152, Problem Identification and Resolution (PI&R)

8 8

OpESS Proposed Details

1. Verify processes are in place to ensure the PRA is maintained with the as-built as operated plant.
2. Verify significant modifications to the plant screened for review and any needed updates to the PRA and the Model of Record.

Guidance applied in 2-stages:

1. Forward looking (Plant changes that being considered for inclusion into the PRA) and,
2. Backward looking (past completed changes, already implemented into the MOR).

Intent would be to revise the OpESS for the subsequent ROP Cycle (2025) based upon observed performance (2024) and refocus, as necessary.

9 9

OpESS Inspections Inspections which would focus on completed changes (i.e., backward-looking):

1.

71111.21M, Comprehensive Engineering Team Inspection, (CETI),

2.

71111.21N.05, Fire Protection Team Inspection (FTPI),

3.

37060, 10 CFR 50.69 Risk-Informed Categorization Inspections which would focus on current in-progress changes (i.e., forward-looking):

Resident Baseline: 71111, (with latitude for possible interactions) 1.

71111.06, Flood Protection Measures, 2.

71111.13, Maintenance Risk Assessments and Emergent Work Control, 3.

71111.18, Plant Modifications (Primary),

4.

71111.24, Testing and Maintenance of Equipment Important to Risk, 5.

71151, Performance Indicator Verification, 6.

71152, Problem Identification and Resolution (PI&R)

10 Criteria to select the OpESS

1.

Implementation of RIP 2.

MOR updates since LA/SE 3.

Timing of last MOR update 4.

SRA Coordination

11 Anticipated OpESS Timeline

  • KM Session in January 2024.
  • Additional Just-in-Time training for inspectors as needed.
  • Limited initial use (Teams inspections initially beginning late 1st quarter to early 2nd quarter).
  • Wider utilization as 2024 progresses.
  • Likely maximum opportunities of 10 CETI and 10 FPTI at most.
  • Limited Resident sites as opportunities arise w/SRA oversight.
  • Not all sites will get sampled in 2024.

12 OpESS Availability

  • DRAFT version is currently available.
  • Final version will be issued and available later in 2023.
  • Effective date anticipated of Jan. 1, 2024; however, not expected to be utilized until later.

13 SDP Key Points

  • 1
  • Keep it simple.
  • Utilize existing processes.

13

14 PCC SDP Proposed DRAFT Pathway More than Minor

  • IMC 0612, App. E, Section 8, Maintenance Rule GREEN
  • SRA/Licensee Coordination

15 DRAFT SDP Pathway for PCC - Details Cross Regional Review Panel proposed screening path:

Pathway utilized for General Guidance

  • IMC 0612, App. B, Issue Screening More than Minor IMC 0612, App. E., Section 8, Maintenance Rule x
  • IMC 0609, Att. 04, Initial Characterization of Findings Go to IMC 0609 App K (Maintenance Risk Assessment) x
  • IMC 0609, App. K, Maintenance Risk Assessment and Risk Management SDP

16 DRAFT Screening Criteria for PCC IMC 0609, App. K, Maintenance Risk Assessment SDP Utilized for General Guidance.

Step 4.2 Determination of Risk Deficit ICDP metric vs. Delta CDF ICDPD = ICDP Actual - ICDP Flawed Deficit (ICDPD) < 1E-6 = GREEN Otherwise perform Detailed Risk Evaluation (DRE)

Proposed exposure duration limited to:

1 year or last model change (most limiting).

17 Questions? / Discussion