ML24109A046
| ML24109A046 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/2024 |
| From: | Lundy Pressley NRC/NRR/DRA |
| To: | Antonios Zoulis NRC/NRR/DRA |
| References | |
| Download: ML24109A046 (6) | |
Text
April 17, 2024 MEMORANDUM TO:
Antonios Zoulis, Chief PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM:
Lundy Pressley, Reliability and Risk Analyst
/RA/
PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MARCH 21, 2024, PROBABILISTIC RISK ASSESSMENT CONFIGURATION CONTROL SIGNIFICANCE DETERMINATION PROCESS PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE AND OTHER INDUSTRY STAKEHOLDERS On March 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held an observation public meeting with the Nuclear Energy Institute (NEI) and Industry, to continue the discussions between the NRC staff, industry stakeholders, and the public regarding enhancing the NRCs oversight of the licensees implementation of its Probabilistic Risk Assessment (PRA)
Configuration Control (PCC) process. Specifically, the staff discussed Significance Determination Process (SDP) proposals related to PCC issues. NRC staff and Industry shared proposed SDP examples on SDP, with most of the discussion focused on minor and more-than-minor criteria. This meeting offered an opportunity for the industry and public to gain familiarity and to provide feedback on the staffs PCC SDP proposal.
The presentation materials for the public meeting are available in Agencywide Document Access and Management System (ADAMS) under the following Package Accession Number.:
(ML24074A275) with the following specific documents: NRC Presentation (ML24074A267);
NRC Draft PCC SDP Examples (ML24074A270), Utility PCC Examples (ML24074A272). The public meeting announcement is available in ADAMS (ML24065A372) and the associated Public Meeting Notification System No.: 20240328. A list of attendees is included in Enclosure
- 1. The details of the meeting and discussion points are contained in Enclosure 2.
As of the date of this summary, the Public Meeting Feedback System has not received any feedback.
No regulatory decisions or commitments were made at the meeting.
Please direct any inquiries to Mr. Lundy Pressley at 404-997-4621 or by email at Lundy.Pressley@nrc.gov.
Enclosures:
- 1. List of Attendees
- 2. Meeting Details
- by e-mail OFFICE NRR/DRA/APOB/RA*
NRR/DRA/APOB/BC
- NAME LPressly AZoulis DATE 4/17/24 4/17/24
LIST OF ATTENDEES MARCH 21, 2024, PRA CONFIGURATION CONTROL SDP PUBLIC MEETING WITH NEI AND OTHER INDUSTRY STAKEHOLDERS Lundy Pressley NRC Andy Rosebrook NRC Antonios Zoulis NRC Rick Deese NRC David Werkheiser NRC Qin Pan NRC John Hanna NRC Pat Finney NRC Matthew Humberstone NRC Meena Khanna NRC Philip McKenna NRC Reinaldo Rodriguez NRC Rick Deese NRC Shane Sandal NRC Sukjoon Kim Argonne National Labs (ANL)
Matthew Degonish AMEREN Justin Hiller AMEREN Isaac Mulhern AMEREN Michael Cymbor Arizona Public Service (APS)
Michelle Carr APS Gary Chung APS Everett Depue APS Mark Hulet APS Michael Wittas APS Enrique Meléndez Consejo de Seguridad Nuclear (Spain)
Jeff Stone CONSTELLATION Patricia Pringle CONSTELLATION Rachelle Johnson CONSTELLATION Roy Linthicum CONSTELLATION Suzanne Loyd CONSTELLATION Philip Tarpinian CONSTELLATION Hero Xavier CONSTELLATION Deann Raleigh CURTIS WRIGHT Robin Ritzman CURTIS WRIGHT Mary Miller DOMINION ENERGY Brian Mount DOMINION ENERGY Clem Littleton DUKE-ENERGY Heather Szews DUKE-ENERGY Jennifer Varnedoe DUKE-ENERGY Robert Rishel DUKE-ENERGY Clem Littleton ENERCON Rob Drsek ENERGY HARBOR Douglas Rapp VISTRA James Laborde ENTERGY Byron Croker ENTERGY Rob Burg EPM Steve Meyer EPM Bruce Morgen EPM Mark Schairer EPM Travis Weber EPM Casey Weiser EPM Fernando Ferrante Electric Power Research Institute (EPRI)
John Richards EPRI David Alford EVERGY Lu Huang EVERGY Jeff Suter EVERGY Paul Nguyen EVERGY David Vu EVERGY Steve Catron FPL Luke Karten FPL Jadie Palenzuela FPL Keith Vincent FPL Brad Tyers GENERAL ELECTRIC Andy Ratchford JENSENHUGHES Victoria Anderson Nuclear Energy Institute (NEI)
Thomas Basso NEI Tim Riti NEI Gary DeMoss Public Service Energy Group (PSEG)
Harry Balian PSEG Cheryl Ann Gayheart SOUTHERN Vish Patel SOUTHERN Kristin Kaspar STPEGS Russell Jones STPEGS Bradley Dolan Tennessee Valley Authority (TVA)
Gerry Kindred TVA Mark Nicholson TVA Eric Browne TVA Damian Mirizio WESTINGHOUSE Adam Stein XCEL ENERGY Greg Kvamme XCEL ENERGY Brian Slack XCEL ENERGY Jason Strickland XCEL ENERGY Phil Couture Unaffiliated Robin Ritzman Unaffiliated
MEETING DETAILS MARCH 21, 2024, PROBABILISTIC RISK ASSESSMENT CONFIGURATION CONTROL SIGNIFICANCE DETERMINATION PROCESS PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE AND OTHER INDUSTRY STAKEHOLDERS Purpose To continue the discussion between the NRC staff, industry stakeholders and the public regarding enhancing the NRCs oversight of the licensees implementation of its Probabilistic Risk Assessment Configuration Control (PCC) process. Specifically, the staff will discuss proposals related to the Significance Determination Process (SDP) with respect to PCC issues.
This meeting will offer an opportunity for the industry and public to provide feedback on the effort and on the staffs recommendation to enhance the oversight efforts associated with PCC.
=
Background===
The objective is to develop a balanced approach for PCC oversight, closing an existing oversight gap in the reactor oversight process (ROP); and to develop the necessary guidance training and qualifications to support inspections in this area.
The current near-term oversight recommendation for PCC includes the use of an operating experience smart sample (OpESS) to be used as an additional tool by inspectors as part of ROP baseline inspection preparation. The information and trends identified from OpESS inspections will provide insight into the long-term oversight recommendations. The OpESS was issued and is publicly available (ADAMS Accession No.ML23255A006).
Meeting Details Mr. Lundy Pressley of the NRC opened the workshop with a presentation (ML24074A267) which included information on PCC background and the SDP proposal. NRC staff then fielded questions related to the SDP proposal.
The meeting then transitioned to a discussion on SDP examples beginning with a discussion on the utilities PCC Examples (ML24074A272), followed by discussing the NRCs PCC SDP Examples (ML24074A270).
NRC staff stated that the focus of the OpESS and any associated SDPs would be on significant safety issues with respect to PRA configuration control and not PRA acceptability.
NRC staff reiterated that the area of PRA configuration control is currently an inspectable and enforceable area at present and that the OpESS and associated proposed SDP is to provide additional guidance in this area.
Industry shared interest in what guidance will be provided to the cross regional review panels. NRC staff stated that consideration will be given to releasing a draft of the guidance for review. A draft copy of that guidance has subsequently been released and is available under ADAMS No. (ML24103A179).
Industry asked the following specific term or definition related questions:
a) Definition of reasonable doubt.
b) Definition of significant.
c) Meaning of adversely change any risk informed decision in an unfavorable manner.
d) Definition of what constitutes operating experience (OpE).
NRC staff answered the above questions as best as possible in relation to PCC issues and relayed that there are currently no defined definitions on these terms within the NRCs Reactor Oversight Process (ROP) framework. NRC staff do not intend to create definitions or deviate from current regulatory practice and will continue to follow current guidelines.
Therefore, specific definitions on these items cannot be provided.
Other industry questions:
Industry asked for clarification on what might constitute no violation at all instead of just minor more than minor. NRC staff communicated the current requirements for what constitutes a performance deficiency, minor violation, and violation, which is contained within IMC 0612 (ML23067A031).
Industry asked if NRC staff plan to make changes to IMC 0609, Appendix K, and NRC staff answered that currently some PCC changes are in progress, however, additional changes may be identified following information gathering from completion of the OpESS.
Industry asked about licensees identifying PCC issues and NRC replied that it is preferable for licensees to identify those issues, which could be considered licensee identified violations (LIV) and that NRC would follow current LIV process regarding PCC issues.
Industry asked a question on exposure and NRC staff stated that the exposure would follow current practice of 1-year or if the issue was related to a recent model change performed within the last year, then the exposure time would be whichever was shorter. In addition, exposure time would be in accordance with current practice of SDP year.
Industry asked about being required to use new methods. NRC staff stated that industry would not be required to use new methods and would only be required to meet the licensing requirements and commitments. NRC staff compared this approach to a backfit.
Industry asked if licensees are required to review all procedure and plant changes. NRC staff replied that it is not expected that licensees review all changes, however, licensees should follow their processes and procedures and generally be aware of what changes will have a significant impact on the PRA model and have controls in place to monitor those changes.
Industry asked if issues or findings will only be related to actual risk assessments. NRC staff replied that all situations are different, however, the comparison was made to current engineering inspections where there are no actual consequences and loss of margin could result in findings. In addition, NRC staff stated that for PCC issues current processes would be followed.
Additional items of discussion:
NRC and industry discussed the NRCs SDP example 1, related to data updates performed within the period of every 2 refueling outages. Industry debated this performance deficiency (PD) and how this would be applicable in practice. There was a debate on the requirements and what this process is in practice and how this example could be confused and misinterpreted. NRC staff agreed to take feedback and continue to review this example.
NRC staff agreed to capturing examples from the cross regional panels, specifically those related to what is considered reasonable doubt.
NRC staff committed to continue to communicate on the utilization of the PCC OpESS and have further open dialogue on the topic. Specifically, NRC staff committed to another public meeting related to PCC SDP, which was schedule for April 18, 2024.