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| number = ML19232A227
| number = ML19232A227
| issue date = 08/20/2019
| issue date = 08/20/2019
| title = 08/21/2019 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 Risk-Informed Process - Slides - Peer Review
| title = NRR E-mail Capture - 08/21/2019 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 Risk-Informed Process - Slides - Peer Revie
| author name = Dinsmore S, Reisi-Fard M
| author name = Dinsmore S, Reisi-Fard M
| author affiliation = NRC/NRR/DRA
| author affiliation = NRC/NRR/DRA
Line 15: Line 15:


=Text=
=Text=
{{#Wiki_filter:Stephen DinsmoreSenior Reliability and Risk AnalystPRA Licensing Branch A 12 1 6NDM Peer Reviews (1/2)New Method High level requirements and supporting requirements are stabilizing and being finalizedExpertise to address some SR may require subject matter experts(NM-B1) "technical bases .. are founded on ... established - engineering principals"F&O closure (Appendix X ?) completed before method reported and usedModifications to "traditional" HLR and SR dispositions both in the self-assessment and the peer review (next
{{#Wiki_filter:NRR-DRMAPEm Resource From:                        Miller, Ed Sent:                        Tuesday, August 20, 2019 9:43 AM To:                          Miller, Ed


slide) 6NDM Key Assumptions (2/2)Modifications to "traditional" HLR and SR dispositions both in the self-assessment and the peer reviewExpectation that the basis for a "met" requirement is fully summarized in the basisThe self-assessment should provide the method developers justification of why the SR is met and reference to supporting information in the reportThe peer review basis should provide the peer reviewers justification of why the SR is metF&O identifying weakness and proposed solutions may be the same as the current F&Os Review of NEI 17-07 Mehdi Reisi-FardActing Branch Chief PRA Licensing Branch B August 21, 2019 Timeline of NEI 17-07 Review Dec. 2017 NEI 17-07 Rev. A was issued(ML17341A548)
==Subject:==
Dec. 2018 Two public meetings were held(ML17341A548)
Slides for Aug 21, 2019, public meeting Attachments:                  Two slides on NEW METHOD peer review HLRs and SRs for 8_21_2019 industry meeting.pptx; Review of NEI 17 Aug 21 2019 public meeting.pptx Attached are Mehdi and Steves slides for the subject public meeting.
NRC provided comments(ML18313B246)
1
Dec. 2018NEI issued Rev. A(ML18352B305)
 
Dec. 2018May-Jun. 2019Three pilot peer-reviews of NDMs NRC provided comments(ML19206A092)Jul. 2019 Aug. 2019NEI 17-07 Rev. 2 was issued(ML19228A242)
Hearing Identifier:    NRR_DRMA Email Number:          183 Mail Envelope Properties      (BYAPR09MB27597E62D61E78BEC23DB37BE9AB0)
Comments on NEI 17-07, Rev. 2NEI 17-07, Rev. 2 allows use of NDMs with open finding level F&Os" - 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 findingsin any risk-informed licensing applications."
 
[emphasis added
==Subject:==
]
Slides for Aug 21, 2019, public meeting Sent Date:              8/20/2019 9:43:29 AM Received Date:          8/20/2019 9:43:31 AM From:                  Miller, Ed Created By:            Ed.Miller@nrc.gov Recipients:
Importance of Closing NDM Open Findings Peer-reviews determine whether requirements of the Standard are met; framework for NDM to be "deemed acceptable" is unclear"The standard requires a peer review process that identifies and assesses where the technical requirements of the standard are not met." [RG 1.200]Unclear how licensees/peer-review of implementation can justify use of NDM with findings (considering lack of expertise, detailed knowledge of NDM, etc.)Review of findings by staff may expand the scope of review to other aspects of methodology   NDM documentation issues may be important as those issues potentially impact implementation of NDM Other Comments on NEI 17-07Page 17: limitedself-assessment of the IEPRA for Internal Flood, Fire, and external hazard PRAsPage 23: "beyond a sampling process" was removedPage 28: Assigning UAM fore use of NDMs with findings was removedPage 34: " - the peer review report should be provided to the NRC by the method developer, with licensee-specific information removed as necessary"Methods submitted will be made publicly available with appropriate redaction of proprietary informationMethod developer has no regulatory requirements to provide the reportsConfusion on the use of "External" and "Other" hazards}}
"Miller, Ed" <Ed.Miller@nrc.gov>
Tracking Status: None Post Office:            BYAPR09MB2759.namprd09.prod.outlook.com Files                            Size                    Date & Time MESSAGE                          73                      8/20/2019 9:43:31 AM Two slides on NEW METHOD peer review HLRs and SRs for 8_21_2019 industry meeting.pptx 376162 Review of NEI 17 Aug 21 2019 public meeting.pptx                  202066 Options Priority:                        Standard Return Notification:            No Reply Requested:                No Sensitivity:                    Normal Expiration Date:
Recipients Received:
 
Some Areas Of Emphasis for Newly Developed Method Peer Reviews Stephen Dinsmore Senior Reliability and Risk Analyst PRA Licensing Branch A 12 1
 
NDM Peer Reviews (1/2)
New Method High level requirements and supporting requirements are stabilizing and being finalized Expertise to address some SR may require subject matter experts (NM-B1) technical bases .. are founded on ...
established  engineering principals F&O closure (Appendix X ?) completed before method reported and used Modifications to traditional HLR and SR dispositions both in the self-assessment and the peer review (next slide) 6
 
NDM Key Assumptions (2/2)
Modifications to traditional HLR and SR dispositions both in the self-assessment and the peer review Expectation that the basis for a met requirement is fully summarized in the basis The self-assessment should provide the method developers justification of why the SR is met and reference to supporting information in the report The peer review basis should provide the peer reviewers justification of why the SR is met F&O identifying weakness and proposed solutions may be the same as the current F&Os 6
 
Review of NEI 17-07 Mehdi Reisi-Fard Acting Branch Chief PRA Licensing Branch B August 21, 2019
 
Timeline of NEI 17-07 Review Dec. 2017               Dec. 2018            May-Jun. 2019              Aug. 2019 NEI 17-07 Rev.           Two public          Three pilot peer-        NEI 17-07 Rev. 2 A was issued              meetings            reviews of NDMs            was issued (ML17341A548)             were held                                     (ML19228A242)
(ML17341A548)
NRC provided         NEI issued Rev. A         NRC provided comments              (ML18352B305)            comments (ML18313B246)                                  (ML19206A092)
Dec. 2018              Dec. 2018                Jul. 2019
 
Comments on NEI 17-07, Rev. 2
* NEI 17-07, Rev. 2 allows use of NDMs with open finding level F&Os
  -   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.
[emphasis added]
 
Importance of Closing NDM Open Findings
* Peer-reviews determine whether requirements of the Standard are met; framework for NDM to be deemed acceptable is unclear
  - The standard requires a peer review process that identifies and assesses where the technical requirements of the standard are not met. [RG 1.200]
* Unclear how licensees/peer-review of implementation can justify use of NDM with findings (considering lack of expertise, detailed knowledge of NDM, etc.)
* Review of findings by staff may expand the scope of review to other aspects of methodology
* NDM documentation issues may be important as those issues potentially impact implementation of NDM
 
Other Comments on NEI 17-07
* Page 17: limited self-assessment of the IEPRA for Internal Flood, Fire, and external hazard PRAs
* Page 23: beyond a sampling process was removed
* Page 28: Assigning UAM fore use of NDMs with findings was removed
* Page 34:   the peer review report should be provided to the NRC by the method developer, with licensee-specific information removed as necessary
  - Methods submitted will be made publicly available with appropriate redaction of proprietary information
  - Method developer has no regulatory requirements to provide the reports
* Confusion on the use of External and Other hazards}}

Latest revision as of 09:50, 1 December 2019

NRR E-mail Capture - 08/21/2019 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 Risk-Informed Process - Slides - Peer Revie
ML19232A227
Person / Time
Issue date: 08/20/2019
From: Stephen Dinsmore, Reisi-Fard M
NRC/NRR/DRA
To: Ed Miller
Special Projects and Process Branch
References
Download: ML19232A227 (10)
v • d • e


Text

NRR-DRMAPEm Resource From: Miller, Ed Sent: Tuesday, August 20, 2019 9:43 AM To: Miller, Ed

Subject:

Slides for Aug 21, 2019, public meeting Attachments: Two slides on NEW METHOD peer review HLRs and SRs for 8_21_2019 industry meeting.pptx; Review of NEI 17 Aug 21 2019 public meeting.pptx Attached are Mehdi and Steves slides for the subject public meeting.

1

Hearing Identifier: NRR_DRMA Email Number: 183 Mail Envelope Properties (BYAPR09MB27597E62D61E78BEC23DB37BE9AB0)

Subject:

Slides for Aug 21, 2019, public meeting Sent Date: 8/20/2019 9:43:29 AM Received Date: 8/20/2019 9:43:31 AM From: Miller, Ed Created By: Ed.Miller@nrc.gov Recipients:

"Miller, Ed" <Ed.Miller@nrc.gov>

Tracking Status: None Post Office: BYAPR09MB2759.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 73 8/20/2019 9:43:31 AM Two slides on NEW METHOD peer review HLRs and SRs for 8_21_2019 industry meeting.pptx 376162 Review of NEI 17 Aug 21 2019 public meeting.pptx 202066 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Some Areas Of Emphasis for Newly Developed Method Peer Reviews Stephen Dinsmore Senior Reliability and Risk Analyst PRA Licensing Branch A 12 1

NDM Peer Reviews (1/2)

New Method High level requirements and supporting requirements are stabilizing and being finalized Expertise to address some SR may require subject matter experts (NM-B1) technical bases .. are founded on ...

established engineering principals F&O closure (Appendix X ?) completed before method reported and used Modifications to traditional HLR and SR dispositions both in the self-assessment and the peer review (next slide) 6

NDM Key Assumptions (2/2)

Modifications to traditional HLR and SR dispositions both in the self-assessment and the peer review Expectation that the basis for a met requirement is fully summarized in the basis The self-assessment should provide the method developers justification of why the SR is met and reference to supporting information in the report The peer review basis should provide the peer reviewers justification of why the SR is met F&O identifying weakness and proposed solutions may be the same as the current F&Os 6

Review of NEI 17-07 Mehdi Reisi-Fard Acting Branch Chief PRA Licensing Branch B August 21, 2019

Timeline of NEI 17-07 Review Dec. 2017 Dec. 2018 May-Jun. 2019 Aug. 2019 NEI 17-07 Rev. Two public Three pilot peer- NEI 17-07 Rev. 2 A was issued meetings reviews of NDMs was issued (ML17341A548) were held (ML19228A242)

(ML17341A548)

NRC provided NEI issued Rev. A NRC provided comments (ML18352B305) comments (ML18313B246) (ML19206A092)

Dec. 2018 Dec. 2018 Jul. 2019

Comments on NEI 17-07, Rev. 2

  • NEI 17-07, Rev. 2 allows use of NDMs with open finding level F&Os

- 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.

[emphasis added]

Importance of Closing NDM Open Findings

  • Peer-reviews determine whether requirements of the Standard are met; framework for NDM to be deemed acceptable is unclear

- The standard requires a peer review process that identifies and assesses where the technical requirements of the standard are not met. [RG 1.200]

  • Unclear how licensees/peer-review of implementation can justify use of NDM with findings (considering lack of expertise, detailed knowledge of NDM, etc.)
  • Review of findings by staff may expand the scope of review to other aspects of methodology
  • NDM documentation issues may be important as those issues potentially impact implementation of NDM

Other Comments on NEI 17-07

  • Page 17: limited self-assessment of the IEPRA for Internal Flood, Fire, and external hazard PRAs
  • Page 23: beyond a sampling process was removed
  • Page 28: Assigning UAM fore use of NDMs with findings was removed
  • Page 34: the peer review report should be provided to the NRC by the method developer, with licensee-specific information removed as necessary

- Methods submitted will be made publicly available with appropriate redaction of proprietary information

- Method developer has no regulatory requirements to provide the reports

  • Confusion on the use of External and Other hazards
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