TSTF-22-10, TSTF Response to NRC Questions on TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program
| ML23032A485 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force, 99902042 |
| Issue date: | 02/01/2023 |
| From: | Lashley P, Lueshen K, Richards A, Sparkman W, Vaughan J BWR Owners Group, PWR Owners Group, Technical Specifications Task Force |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TSTF-22-10, TSTF-591 | |
| Download: ML23032A485 (1) | |
Text
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF February 1, 2023 TSTF-22-10 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" On October 11, 2022, the NRC provided a Request for Additional Information (RAI) regarding TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" (Agencywide Documents Access and Management System Accession No. ML22081A224).
The TSTF's response to the NRC RAI is attached.
Should you have any questions, please do not hesitate to contact us.
Andrew M. Richards, Jr. (PWROG/W)
Phil H. Lashley (BWROG)
Kevin Lueshen (PWROG/CE)
Jordan L. Vaughan (PWROG/B&W)
Wesley A. Sparkman (PWROG/AP1000)
Attachment cc:
Michelle Honcharik, Technical Specifications Branch Victor Cusumano, Technical Specifications Branch
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-1 The NRC request is repeated below in italics, followed by the TSTF response.
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. 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
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-2 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).
Response
- a.
The proposed TS requires the licensee to maintain and upgrade the PRA used to calculate a RICT in accordance with the processes endorsed in the regulatory positions of RG 1.200, Revision 3, which endorses NEI 17-07, Revision 2. NEI 17-07, Revision 2, Section 9.2 states, "if a newly developed method is deemed not technically acceptable in the report, a utility may not use it in a PRA supporting risk-informed licensing applications. If the method is deemed technically acceptable, but if one or more finding level F&Os are issued in the report, the utility will need to justify the use of the method with these open findings in any risk-informed licensing applications." RG 1.200, Revision 3, Regulatory Position C.2.2.2.2, states, "If open 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."
The proposed Risk Informed Completion Time (RICT) Program Upgrade Report is submitted for information only and does not request NRC approval, and would not satisfy Regulatory Position C.2.2.2.2.
As a result, the report that will be submitted to the NRC for NDM use in the RICT program can only be used to describe NDMs that are technically acceptable with all the open F&Os resulting from the technical review of the NDM closed using an NRC-endorsed peer-review process.
- b.
As stated in RG 1.200, Revision 3, Regulatory Position C.2.2.2.2, if the peer review of the NDM has open finding-level F&Os that cannot be closed via an NRC-endorsed peer review process, the NDM must be submitted to the NRC for approval prior to use. Note that NEI 17-07, Revision 2, refers to open findings regarding the method (i.e., technical), not open findings regarding the licensee-specific implementation of the method.
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-3 The submittal to the NRC referenced in Regulatory Position C.2.2.2.2 could be in the form of a topical report submitted for NRC endorsement or a plant-specific license amendment request submitted under 10 CFR 50.90 for NRC approval.
- c.
As stated in NEI 17-07, Revision 2, if an NDM is deemed not technically acceptable in the NDM peer review report, or if at least one finding-level F&O on the NDM remains open, a licensee or applicant may not use it in a PRA supporting risk-informed licensing applications without prior NRC approval. As discussed in response to question 1.b, NRC approval would be by approval of a topical report or license amendment. The traveler proposed report would only apply to NDMs that were found to be acceptable without NRC prior approval following the process described in NEI 17-07, Revision 2 and RG 1.200, Revision 3, Regulatory Position C.2.2.2.2. The proposed Risk Informed Completion Time (RICT) Program Upgrade Report cannot be used to satisfy Regulatory Position C.2.2.2.2 as it is submitted for information and NRC approval is not requested.
- d.
Proposed paragraph g states that a report must be submitted before an NDM is used to calculate a RICT. This paragraph does not discuss what constitutes an acceptable NDM to be used by the licensee. Proposed paragraph f discusses the upgrade of PRA models to be used to calculate a RICT, which could include the use of NDMs. Paragraph f requires using the processes endorsed in RG 1.200, Revision 3, which includes NEI 17-07, Revision 2, and PWROG-19027-NP, Revision 2. As discussed in the response to questions 1.a-1.c, NEI 17-07, Revision 2, and RG 1.200, Revision 3, are clear that NDMs with open finding-level F&Os may not be used by a licensee without prior NRC approval. Therefore, additional clarification is not required.
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-4 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 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
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-5
- 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.
Response
- a.
NEI 17-07, Revision 2, does not require an NRC determination that an NDM is acceptable for use in the RICT Program unless the peer review of the NDM has one or more open finding-level F&Os.
The RG 1.200, Revision 3, definition of "consensus method" states, "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."
PWROG-19027-NP, Revision 2, Section 5.2.2, "Public Availability of NDM Peer Review Reports," states (emphasis added):
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).
The proposed Risk Informed Completion Time (RICT) Program Upgrade Report, paragraph b, requires inclusion of, "A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, 'Newly Developed Method Requirements and Peer Review'."
Therefore, submittal of the proposed Risk Informed Completion Time (RICT) Program Upgrade Report would be consistent with example c, above. The submitted report provides the public basis for the technical review and acceptability of the NDM and the peer review.
TSTF Response to NRC Questions on TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program" Page A-6 Therefore, the method satisfies the RG 1.200, Revision 3, definition of a consensus method.
There is no need for other licensees to submit a specific report, as licensees using the NDM would do so using the provisions of RG 1.200, Rev. 3, with the supporting documentation of the docketed report.