PWROG-19027

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Portions endorsed by Regulatory Guide 1.200 revision 3.

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1 INTRODUCTION

The Pressurized Water Reactor (PWR) Owners Group (PWROG) Project Authorization (PA)

RMSC-1647 (Reference 1) supported the interaction between the PWROG Risk Management

Committee (RMSC), the United States Nuclear Regulatory Commission (USNRC), the Boiling

Water Reactor Owners Group (BWROG) and the Nuclear Energy Institute (NEI) for the

development of technical requirements that can be used evaluate the technical adequacy of a

Newly Developed Method (NDM) to be adopted in a plant Probabilistic Risk Assessment (PRA).

The objective of this program is to provide clear criteria for the review of NDMs used in support

of risk informed applications. This PWROG project develops the definitions, processes and

technical requirements necessary to implement NDMs. Concurrent and parallel modification by

the NEI of the PRA peer review process documented in NEI 17-07 (Reference 2) accommodates

the review of new methods. This report includes the resolution of comments from the USNRC

that were discussed at a public meeting on August 21st, 2019 (Reference 3).

Ultimately, the intent is that the requirements for the newly developed method be added in the

future edition of the Standard for Level 1/Large Early Release Frequency Probabilistic Risk

Assessment for Nuclear Power Plant Applications that is being developed by the American

Nuclear Society (ANS) and American Society of Mechanical Engineers (ASME) Joint Committee

on Nuclear Risk Management (JCNRM).

Revision 2 of this report considers feedback from the JCNRM following the December 2019 ballot

for the next edition of the Standard and interaction between the PWROG and commenters of the

PRA Standard.

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2 DEFINITION OF NEWLY DEVELOPED METHOD

A number of operating definitions are needed to support the development of the NDM

requirements and review process. The following definitions are therefore proposed to be included

in the update of Section 1-2.2 of the ASME/ANS PRA Standard. For each definition, multiple

sources were used, including the current versions of the PRA Standard (Reference 4), the

combined NEI peer review guidance (Reference 2), the USNRC Regulatory Guide (RG) 1.200

(Reference 5), and the ANS glossary (Reference 6). The resulting proposed definitions take into

considerations all these sources and modify the definitions as judged to be needed for the

purposes of the PRA Standard.

PRA Upgrade: A change in the PRA that results in the applicability of one or more

Supporting Requirements (SRs) that were not previously included within the PRA (e.g.,

performing qualitative screening in Part 4 when this HRL was previously not applicable or

the addition of a new hazard model), an implementation of a PRA method in a different

context, or the incorporation of a PRA method not previously used.

PRA Method: An analytical approach used to satisfy a supporting requirement or

collection thereof in the PRA. An analytical approach is generally a compilation of the

analyses, tools, assumptions, and data used to develop a model.

Model: A qualitative and/or quantitative representation that is constructed to portray the

inherent characteristics and properties of what is being represented (e.g., a system,

component or human performance, theory or phenomenon). A model may be in the form,

for example, of a structure, schematic or equation. Method(s) are used to construct the

model under consideration.

PRA: A quantitative assessment of the risk, including technical elements for modeled

hazards, associated with plant operation and maintenance that is measured in terms of

frequency of occurrence of risk metrics, such as core damage or a radioactive material

release and its effects on the health of the public [also referred to as a probabilistic safety

assessment (PSA)]

PRA Maintenance: A change in the PRA that does not meet the definition of PRA

upgrade.

State-of–Practice: Those practices that are widely implemented throughout the

commercial nuclear power industry, have been shown to be technically acceptable in

documented analyses or engineering assessments, and have been shown to be

acceptable in the context of the intended application.

Consensus Method/Model: A method/model that the USNRC has used or accepted for

the specific risk-informed application for which it is proposed.

The above definitions allow for the definition of an NDM as follows:

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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 stateof-practice method. A newly developed method is not a state-of practice or a consensus

method.

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3 USE OF NEWLY DEVELOPED METHODS IN PLANT PRA

A new method can be used to expand or refine an existing PRA but is always envisioned to be an

upgrade, which implies a focused scope peer review of an existing PRA. If a new method is used

in a PRA, it is necessary to confirm whether the new method that is applied meets the definition

of newly developed method.

With the definitions discussed in the previous section, the process described in the following

Figure 3-1 can be therefore considered.

Figure 3-1: Peer Review Determination Process

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Step 1a: Does the change apply a method not previously used?

Based on the definition of a PRA method that is provided above, in this Step, the analyst should

review the change to determine if a new analytical approach was used to meet any SRs.

Step 1b: Does the new method is a consensus method

If the method was already successfully reviewed through the NDM review process or is a

consensus method, then there is no need for assessment of its technical adequacy and only a

peer review of the application of the method is needed.

Step 1c: Does the change represent a “Newly Developed Method”?

In this step, the analyst should evaluate whether the change would represent a Newly Developed

Method as defined above. If the new method simply represents implementation of a state-ofpractice method that was not previously implemented in the plant PRA being changed, this would

be categorized as a PRA Upgrade.

Step 2: Are any new SRs applicable (including new Hazards)?

This step defines a PRA upgrade as those PRA changes that support any SRs that were

previously not reviewed or were previously not applicable (N/A) are now applicable and should

be reviewed. It is noted that this includes new hazards or new parts of the ASME/ANS PRA

Standards.

If the original PRA Peer review was performed against Capability Category (CC) CC-I of the

standard, any PRA changes that were made that support SRs moving from CC-I to CC-II are

considered an upgrade.

The definitions of “state-of-practice”, “consensus method”, “PRA method”, and “newly developed

method” are provided in Section 2 and are used to decide whether a PRA method needs to

undergo a dedicated peer review against the requirements presented in Section 4.

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4 REQUIREMENTS FOR NEWLY DEVELOPED PRA METHODS

This section summarizes the recommendations to JCNRM pertaining to the definition of a new

set of requirements for newly developed PRA methods and specific expectations for the peer

reviews of such methods. The generic expectation is that newly developed methods satisfy the

set of requirements discussed in this section. This section is to be considered in conjunction with

the proposed definitions of state of practice and of newly developed method; based on these

definitions (see Section 2) it is clear that there is no expectation to retroactively apply these

requirements to every method used in every PRA, however, it is expected that methods used in

a PRA will generally meet these requirements in principal.

The requirements have been discussed in dedicated workshops with PWROG, BWROG, NEI,

USNRC and JCNRM representatives. Three (3) pilots peer reviews have been performed

following an initial drafting of the requirements and of the peer review expectations (see

References 7, 8 and 9). The requirements documented in this report incorporate feedback and

lessons learned from such pilots as well from a review performed by JCNRM members not

involved in the development of the requirements.

It is recommended that requirements for assessing the technical adequacy of a newly developed

method used in PRA be documented in a new section (e.g., Section 1-7) of Part 1 of the PRA

Standard. The following wording is recommended to be added in the new section.

Section 1-7

Newly Developed Methods

1-7.1 INTRODUCTION

This Section states requirements for newly developed

methods explicitly developed for use in PRA to support

risk-informed decisions for nuclear power plants. The high

level and supporting requirements for the Newly

Developed Methods are contained in Tables 1.7.2-1

through 1.7.2-7.

1-7.2 OBJECTIVE

The objective of the newly developed method

requirements is to ensure that a newly developed

method is technically adequate and are as follows:

a) The newly developed method has clearly

defined scope and limitations

b) The newly developed method is based on

sound engineering and relevant science

c) The newly developed method has proper

treatment of assumptions and uncertainties

d) The newly developed method is based on

appropriate and well understood data

e) The newly developed method produces results

that are consistent with expectations

f) The newly developed method is clearly

documented in such a way that knowledgeable

personnel can understand them without

ambiguity and that there is enough

documentation so that it can be peer reviewed.

The objectives above are intended to be applicable

to a large spectrum of methods, although it is

understood that not all the supporting requirements

could be applicable to all methods. In some cases,

depending on the method scope and purpose, some

of the SRs may not be applicable. In addition, the

SRs are designed to be able to address a stand-alone

method (i.e., independent from its implementation

on a specific plant PRA). It is recognized that, in

some circumstances, a method can be so plant or site

specific (especially in the external hazard domain)

that a full review of the method can only be

performed within its implementation. In such cases,

it is envisioned that some of the NM SRs could be

overlapping with Part specific SRs (e.g., SRs in Part

8). In such cases, the technical SRs in the appropriate

part may take priority to some NM SRs.

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Designator Requirement

HLR-NM-A The purpose and scope of the newly developed method shall be clearly stated.

HLR-NM-B The newly developed method shall be based on sound engineering and science relevant to

its purpose and scope.

HLR-NM-C The data (note that data can be numeric or non-numeric in nature) shall be relevant to the

newly developed method, technically sound, and properly analyzed and applied.

HLR-NM-D Uncertainties in the newly developed method shall be characterized. Sources of model

uncertainties and related assumptions shall be identified

HLR-NM-E

The results of the newly developed method shall be reproducible, reasonable and consistent

with the assumptions and data, and given the purpose and scope of the newly developed

method.

HLR-NM-F The documentation of the newly developed method shall provide traceability of the work

and facilitate incorporation of the newly developed method in a PRA model.

Table 1-7.2-2 Supporting Requirements for HLR-NM-A

The purpose and scope of the newly developed method shall be clearly stated (HLR-NM-A).

Index No.

NM-A Requirement

NM-A1

ENSURE that the stated purpose of the newly developed method (i.e., what is being

achieved by the newly developed method) is consistent with the scope (established

boundary) of the newly developed method.

NM-A2 ENSURE that the applicability and limitations of the newly developed method are

consistent with the purpose and scope in NM-A1.

NM-A3

Based on the limitations and applicability of the newly developed method, IDENTIFY

which areas of the PRA for which the newly developed method is intended to be used, and

those for which it is specifically not intended for (e.g., hazards, technical elements, plant

features, SRs impacted by the newly developed method).

Table 1-7.2-3 Supporting Requirements for HLR-NM-B

The newly developed method shall be based on sound engineering and science relevant to its purpose and scope

(HLR-NM-B).

Index No.

NM-B Requirement

NM-B1

ESTABLISH the technical bases for the newly developed method by using approaches

founded on established mathematical, engineering and/or scientific principles (e.g.,

established through operating experience, tests, benchmarking, or acceptance by the

scientific community).

NM-B2

If empirical models are used, ENSURE that they are supported by sufficient data which is

relevant to the newly developed method and, to the extent possible, that the experimental

data are shown to be repeatable.

NM-B3 IDENTIFY assumptions used to develop the technical bases of the newly developed

method.

NM-B4 JUSTIFY the rationale for the assumptions identified in NM-B3 (e.g., backed by appropriate

operational experience).

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Table 1-7.2-4 Supporting Requirements for HLR-NM-C

The data (note that data can be numeric or non-numeric in nature) shall be relevant to the newly developed

method, technically sound, and properly analyzed and applied (HLR-NM-C).

Index No.

NM-C Requirement

NM-C1

IDENTIFY the data needed to support the development of the newly developed method

(e.g., relevant plant-specific data, industry-wide current operating experience and data, or

experimental or test data).

NM-C2 COLLECT relevant data consistent with current technical state-of-practice.

NM-C3 DEMONSTRATE that the data used, including experimental data or test data, is relevant to

and supports the technical basis of the newly developed method.

NM-C4 SPECIFY the basis for exclusion of data identified in NM-C1.

NM-C5 ANALYZE data (e.g., modifications to the data, use of data in a different context or beyond

the original ranges, statistical analysis) using technically sound basis or criteria.

NM-C6 ENSURE that data is applied consistent with the purpose and scope of the newly developed

method.

Table 1-7.2-5 Supporting Requirements for HLR-NM-D

Uncertainties in the newly developed method shall be characterized. Sources of model uncertainties and related

assumptions shall be identified (HLR-NM-D).

Index No.

NM-D Requirement

NM-D1

Note (1)

CHARACTERIZE the parameter uncertainties associated with the newly developed

method consistent with the intended scope and purpose of the method; this

characterization could include, for example, specifying the uncertainty range,

qualitatively discussing the uncertainty range, or identifying the parameter estimate

as conservative or bounding.

NM-D2 IDENTIFY the sources of model uncertainty associated with assumptions identified in

NM-B3.

NM-D3

CHARACTERIZE the model uncertainties (identified in NM-D2) associated with the

newly developed method; this characterization may be in the form of sensitivity

studies.

Notes:

(1) Depending on the purpose and scope of the method, uncertainty distributions may need to be

explicitly calculated to allow for application of a method for risk significant items to meet Capability

Category II of related technical SRs in other parts of the Standard.

Table 1-7.2-6 Supporting Requirements for HLR-NM-E

The results of the newly developed method shall be reproducible, reasonable and consistent with the

assumptions and data, and given the purpose and scope of the newly developed method (HLR-NM-E).

Index No.

NM-E Requirement

NM-E1

REVIEW the results from the newly developed method to determine that they are

reproducible, reasonable and consistent with assumptions and data addressed in the SRs

under HLR-NM-B and HLR-NM-C.

NM-E2 COMPARE the results of the newly developed method with existing methods and, when

possible, IDENTIFY causes for substantial differences.

NM-E3 ENSURE uncertainties do not preclude meaningful use of the newly developed method

results.

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Table 1-7.2-7 Supporting Requirements for HLR-NM-F

The documentation of the newly developed method shall provide traceability of the work and facilitate

incorporation of the newly developed method in a PRA model (HLR-NM-F).

Index No.

NM-F Requirement

NM-F1

DOCUMENT the newly developed method specifying what is used as input, the technical

basis and the implementation expectations and limitations by addressing the following, as

well as other details needed to fully document how the set of the NM SRs are satisfied:

(a) the purpose and scope of the newly developed method

(b) the intended use of the newly developed method

(c) the limitations of the newly developed method

(d) the detailed technical basis for the newly developed method

(e) the data source, collection process and data manipulation performed in support of

the newly developed method

(f) the assumptions and uncertainties associated with the newly developed method

(g) the interpretation of the results of the newly developed method in the framework of

the intended use and application

NM-F2

DOCUMENT the intended process by which the newly developed method can be applied

to a PRA model consistently with the intended use of the newly developed method and

taking into account the purpose, scope and limitations.

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5 PEER REVIEW FOR NEWLY DEVELOPED METHODS

This section discusses potential clarifications and modifications of the peer review program to

accommodate a peer review of method for which, using the criteria and definition defined above,

it is concluded that a peer review is needed. NEI 17-07 (Reference 2) addresses the specifics of

the peer review; this section is not presenting updates specific to NEI 17-07 but rather generic

clarifications on the process.

5.1 CHANGES TO THE PEER REVIEW SECTION IN THE PRA STANDARD

The following specific changes in Part 1 of the PRA Standard are recommended. Sections not

mentioned here below are considered fully applicable (i.e., no recommended changes).

It is recommended that Section 1-6.1.1 (Documentation and Self-Assessment) be removed

completely. The documentation of a self-assessment is part of the process and is captured in

NEI-17-07. It does not need to be included in the Standard.

It is recommended that Section 1-6.1.4 (Method) be rewritten as follows:

1-6.1.4 Peer Review Process

The review shall be performed using a written process that assesses the requirements of the

Technical Requirements section of each respective Part of this Standard and addresses the

requirements of the Peer Review Section of each respective Part of this Standard.

The peer review process shall consist of the following elements:

(a) selection of the peer review team

(b) training in the peer review process

(c) an approach to be used by the peer review team for assessing if the PRA meets the

supporting requirements of the Technical Requirements section of each respective Part

of this Standard

(d) management and resolution of potential differing professional opinions

(e) documentation of the results of the review

When included in the scope of a peer review, a newly developed method shall be reviewed

following the dedicated requirements discussed in Section 1-7.

It is recommended that Section 1-6.2.2 (Individual Team Members) be rewritten as follows:

1-6.2.2 Individual Team Members

The peer review team members individually shall be:

(1) knowledgeable of the requirements in this Standard for their area of review

(2) experienced in performing the activities related to the PRA Technical Elements for

which the reviewer is assigned

(3) independent from the team that developed the PRA model or the method being peer reviewed.

(4) Subject matter experts should be included to judge the technical adequacy of non-PRA

engineering evaluations and to confirm that the applicable envelope defining the limits of the

method are identified.

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It is recommended that Section 1-6.2.3 (Review Team Members for PRA Upgrades) be removed

completely.

It is recommended that Section 1-6.3 be rewritten as follows:

1-6.3 REVIEW OF PRA TECHNICAL ELEMENTS

The peer review team shall use the requirements of this section, as complemented by hazard

specific requirements presented in the Peer Review Section of each respective Part of this

Standard for the PRA. These hazard-group–specific requirements are stated in the

corresponding peer review section of each Part (e.g., 2-3.3, 3-3.3). The peer review team shall

review the technical requirements of the hazard group to determine if the method and the

implementation of the method for each PRA Technical Element meet the requirements of this

Standard. Additional material for those Elements may be reviewed depending on the results

obtained. The judgment of the reviewer shall be used to determine the specific scope and depth

of the review in each PRA Technical Element.

The results of the appropriate hazard group PRA, including models and assumptions, and the

results of each PRA Technical Element shall be reviewed to determine their reasonableness

given the design and operation of the plant (e.g., investigation of cutset or sequence

combinations for reasonableness).

The PRA configuration control program is reviewed against the requirements presented in

Section 1-5; any newly developed method included in the scope of the peer review is reviewed

against the requirements of Section 1-7. It is noted that a newly developed method can be peer

reviewed within the scope of a plant PRA (i.e., concurrently with its implementation in a plant

PRA) or via a dedicated stand-alone peer reviewed. In this second case the implementation of

the method is peer reviewed in a separate peer review.

Even if exceptions to the requirements of Section 1-6.2.4(c) occur, concerning the composition

of the peer review team or the duration of the review, all SRs relevant to the scope of the peer

review of the PRA are to be reviewed.

The extent of a focused-scope peer review includes all Supporting Requirements (e.g., not just

those for which Findings were cited), within the High Level Requirement(s) containing

Supporting Requirements with Findings. New Findings may be issued even for Supporting

Requirements that did not have previous Findings since a focused-scope peer review

encompasses all the Supporting Requirements within an affected High Level Requirement.

It is recommended that Section 1-6.6.1 be rewritten as follows:

1-6.6.1 Peer Review Team Documentation

The peer review team’s documentation shall demonstrate that the review process appropriately

implemented the review requirements.

Specifically, the peer review documentation shall include the following:

(a) identification of the version of the PRA reviewed

(b) a statement of the scope of the peer review

(c) the names of the peer review team members

(d) a brief resume on each team member describing the individual’s employer, education, PRA

training, and PRA and PRA Technical Element experience and expertise

(e) the elements of the PRA reviewed by each team member

(f) a discussion of the extent to which each PRA Technical Element was reviewed, including

justification for any supporting requirements within the peer review scope that were not

reviewed

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(g) results of the review identifying any differences between the requirements in the Technical

Requirements section of each respective Part of this Standard and Section 1-5 and the method

implemented, defined to a sufficient level of detail that will allow the resolution of the

differences

(h) identification and significance of exceptions and gaps relative to the Standard’s requirements,

in sufficient detail to allow the resolution of the gaps that the peer reviewers have determined

to be material to the PRA

(i) an assessment of PRA assumptions that the peer reviewers have determined to be material to

the PRA

(j) differences or dissenting views among peer reviewers

(k) recommended alternatives for resolution of any differences

(l) an assessment of the CC of the SRs (i.e., identification of what CC is met for the SRs)

It is recommended that Section 1-6.6.2 be rewritten as follows:

1-6.6.2 Resolution of Peer Review Team Comments

Resolution of Peer Review Team comments (Facts and Observations (F&Os) shall be

documented. The resolution of the F&Os findings shall describe how the deficiency was

addressed such that the associated SR can now be demonstrated to be met.

Emphasis is given on whether an F&O is resolved via a PRA maintenance or a PRA upgrade.

A focused scope peer review is performed to address any PRA upgrade.

It is recommended that Section 1-6.6.3 be removed completely as it is now addressed by

Section 1-7.

There is no need to make any change in the hazard specific peer review sections (e.g.,

Section 2-3), as there is nothing hazard-specific that needs to be addressed in the review of a

method.

5.2 NEWLY DEVELOPED METHOD PEER REVIEW REPORT

This section discusses the structure and content of a NDM peer review report.

If the NDM is peer reviewed in conjunction with a plant PRA and is documented as part of the

plant PRA peer review, dedicated sections in the reports need to be created for the NDM review

portion of the review, including the same content discussed below.

5.2.1 NDM Peer Review Report Structure and Content

The following is the recommended content of the report for a NDM peer review.

Introduction

Purpose

A short description of the purpose of the report.

Scope

The method that is being peer reviewed needs to be uniquely identified.

Also, it should be clarified which technical supporting requirements should be

peer reviewed when the NDM is applied to a plant PRA

Peer Review Process

Overview of Review Process

A short summary of the process used needs to be presented, mainly with

reference to the NEI peer review guidance and to the PRA Standard (or to the

document that contains the review requirements).

Peer Review Schedule and Reviewer Assignments

A short summary of the steps followed during the review process.

A very short biography of all the peer review team members that confirms the

reviewer’s qualifications and pre-requisites should be provided.

Reviewed Information

All the documentation reviewed in support of the NDM review should be listed.

Summary of Review Results and Observations

Method Characterization

The reviewer’s understanding of how the method that was reviewed qualifies

as a newly developed method, based on the NDM definition.

If a NDM is an evolution of existing methods, it would be helpful to provide

indications of whether the original methods were already peer reviewed (or

being part of a plant PRA that was peer reviewed)

Technical Adequacy

A summary of each SRs in the NDM section of the Standard is met, not met,

not reviewed or not applicable. A short rationale needs to be provided for each

SR that is judged not applicable.

For each applicable SRs, facts and observations linked to the SR should be

provided (this is a summary, although all detailed F&O wording needs also to

be provided).

Assessment of the Requirements

Documentation of the reviewer assessment for each SR that is judged

applicable. The assessment should explicitly indicate the basis for the SR

assessment as met or not met.

Facts and Observations

F&Os written against the method.

Conclusions

A summary of the overall report. A positive statement on the technical adequacy of

the method needs to be repeated for clarity in the conclusions.

Reviewer Resumes and Qualification Review

Documentation of the reviewer pre-requisites along with each review team

members resume.

The judgment of the review lead about the review team meeting the reviewer

qualification requirements.

The method owner acceptance of the review team and concurrence on the

qualification.

An appendix has to be provided that includes a short summary of the overall

review with no proprietary information. The minimum information needed in this

section is:

a. Unique identification of the method reviewed
b. Process followed for the review (i.e., reference to NEI guidance)
c. Review team composition (full resume not required)
d. Method characterization and technical adequacy summary
e. SR assessments and associated basis
f. F&Os wording and/or basis for closure of F&Os.
g. List of SRs to be peer reviewed in a focused scope review applying the method

Alternatively, if the full NDM peer review report is determined to be non-proprietary, the full report can be made publicly available; in this case the non-proprietary summary would not be needed.

5.2.2 Public Availability of NDM Peer Review Reports

While there is no expectation that the full NDM peer review report is made publicly available, the non-proprietary Appendix of the peer review report is expected to be made available to the public so that both the NRC and any utility applying in the future for the method can reference the fact that the method has been peer reviewed.

There is no mandatory vehicle to be used to ensure public availability of the non-proprietary

appendix of the peer review report but the following mechanisms can be considered as examples:

a. The non-proprietary appendix of the peer review report can be made available on the web site of the method developer and owner organization (e.g., EPRI, PWROG, etc.)
b. The appendix can be added in an Appendix to the method primary report (e.g., EPRI report)
c. The appendix can be made available to the NRC to be loaded on ADAMS (no formal request of review or endorsement would be needed). Note that “publicly available” is not necessarily to be intended as “for free”.

5.3 PRA METHODS PEER REVIEW OUTCOME

The following Figure 5-1 summarizes the possible outcomes from an NDM peer review and the

repercussion on the use of the method in a plant PRA model. Beyond the proposed peer review

process, submittal of the method to the NRC for a direct assessment remains a valid option.

If the suggested peer review process is used to assess the technical adequacy of the method,

then two main possible outcomes from a newly developed method peer review are:

a. If all the NM SRs are MET and there are no open findings, the method is considered

technically adequate and can be implemented in a plant PRA. Following implementation,

the plant will undergo a focused scope peer review where the review team will assess if

the method is adequately applied to the plant PRA and is performed against the technical

supporting requirements in the relevant Part(s) of the PRA Standard.

b. If there are NM SRs that are NOT MET or there are open finding against some NM SRs,

the conclusion will be that the newly developed method is NOT technically adequate. In

this situation, it would not be recommended for a plant to apply the method in the plant

PRA. It is possible to envision that some of the open findings may be easy to disposition

(e.g., a minor documentation finding or related to a portion of a method that is not used by

the plant). It becomes the plant responsibility to address those findings in the application

of the method in the plant PRA.

The F&O closure process (see Appendix E of Reference 2) can be used to close findings

associated with an NDM. It is to be noted that the F&O closure process requires the

developer of the method (and the independent assessment team) to evaluate whether a

finding is closed through a maintenance or an upgrade activity (which would result in the

need for a follow up NDM peer review to be performed). Note that the operating definitions

of PRA upgrade and PRA maintenance may not be directly applicable to a PRA method.

However, the concept remains valid when considering that a PRA method maintenance

activity would be:

 a correction of an error that does not change the intent or the conclusions for

the method;

 the processing of more input data with the same process that does not change

in the intent of the conclusion of the method;

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 the expansion of documentation for data and assumptions already used (but not

appropriately documented in origin);

 performance of more sensitivities to discuss uncertainties and or to confirm the

applicability of the method within the original intended range of application;

 clarification of the documentation in support to implementation of the method.

A PRA method upgrade activity would be an action that changes the intent of the method,

such as:

 extension/change of the scope/applicability of the method;

 a fundamentally different way to process input/output data (beyond usage of a

different tool to perform the same process function)

Following an F&O closure review and/or a focused scope peer review for the NDM, an

update of the summary information needs to be made again available to the public to

document the new technical adequacy assessment.

Figure 5-1: Newly Developed Method Peer Review Flow Chart

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6 CONCLUSIONS

The PWROG worked with a number of stakeholders to define a set of technical requirements to

be associated to a method used in PRA for a plant. A number of definitions were also proposed

that would support a process for which newly developed methods could be explicitly peer

reviewed within the PRA peer review program to ascertain the technical adequacy of the method.

Specific changes to the upcoming edition of the ANS/ASME PRA Standard are proposed in this

report to support the NDM definition, technical requirements and per review process. This

document would enable the upcoming NEI peer review guidance to support and manage the

review of NDMs concurrently or before their implementation in a plant PRA.

An efficient process for the review of NDMs would support a more streamlined acceptance by the

USNRC of PRA changes in support to risk-informed application and license amendments.

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7 REFERENCES

1. PA-RMSC-1647, R1 Model Maintenance vs Upgrade Workshop.

2. NEI 17-07, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard.

Revision 2, August 2019. (ADAM ML19228A242).

3. Public Meeting with the Nuclear Energy Institute to Discuss the Use of New Probabilistic

Risk Assessment Methods Following the Issuance of an Amendment to Utilize a RiskInformed Process. August 21st, 2019. (ADAM ML19207A443).

4. ASME/ANS RA-Sb-2013, Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large

Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant

Applications.

5. USNRC Regulatory Guide 1.200, Revision 2, An Approach for Determining the Technical

Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities. March

2009. (ADAM ML090410014).

6. American Nuclear Society, Standard Committee. Glossary of Definitions and Terminology

(as of April 2019). Available on the ANS web site: http://www.ans.org/standards/toolkit/

7. PWROG-19019-NP, Revision 0-A, Newly Developed Method Peer Review Pilot – EDG

Component Reliability Data Development – PA-RMSC-1647. June 2019.

8. PWROG-19020-NP, Revision 1, Newly Developed Method Peer Review Pilot – General

Screening Criteria for Loss of Room Cooling in PRA Modeling – PA-RMSC-1647. April 2020.

9. Draft Jensen Hughes report BD000000.000-RPT-01 – Newly Developed Method Peer

Review Pilot – fraction of Complete Fire Damage to a NUREG-2178 Vol 1 Group 4 Electrical

Cabinet. Draft 0a as of June 2019.

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PWROG-19027-NP Revision 2 Proprietary Class 3

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Approval Information

Author Approval Maioli Andrea Jul-10-2020 18:01:02

Reviewer Approval Labarge Nathan R Jul-13-2020 13:01:32

Manager Approval Sadlon Dan Jul-13-2020 14:35:15

Manager Approval Mirizio Damian S Jul-27-2020 12:57:50

Files approved on Jul-27-2020

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