ML23271A006

NRC Staff Slides for PWROG Rmc Meeting August 2023

ML23271A006
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Issue date:	08/16/2023
From:	Mike Franovich NRC/NRR/DRA
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Risk Management Committee Meeting PWROG Meet i ng August 16, 2023

Michael X. Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation

1 Agenda

Introduction - Mike Franovich September NRC Risk Workshop - Jen Whitman RAPTR Updates - Michelle Kichline POAHNI Seismic Update - Shilp Vasavada Digital CCF roadmap for design - Sunil Weerakkody SPAR Model Updates - Qin Pan PRA config control update - Lundy Pressley

2 Key Topics of Interest

+ Sustaining RIDM expectations within NRR

• SPAR-DASH - realism in SPAR models

• LIC-206 Integrated Review Teams

• 2023 NRC Risk Forum

+ High-burnup fuel and increased enrichment rulemaking activities (source terms, dose consequences)

+ Risk-informed and Performance-based approaches for licensing basis events

+ International activities

3 NRC International Strategy

Advance risk management concepts through international standards and guidance for graded approaches in licensing and oversight of operating and new reactors

IAEA No. SSR-2/1, Safety of Nuclear Power Plants: Design IAEA No. SSG-3, Development and Application of Level 1 Probabilistic Safety Assessment for Nuclear Power Plants IAEA TECDOC-1980, Application of a Graded Approach in Regulating Nuclear Installations 6 4 September 12th NRC Ri sk Workshop

To discuss successes in leveraging risk -informed decision-making (RIDM) across the operating reactor, new reactor, and advanced reactor business lines, and path forward for expanding use of RIDM across business lines

5 Diversity of perspectives and topics

+ Risk-Informed Initiative Success Stories and Path Forward

• Shilp Vasavada, Chief, PRA Licensing Branch C at NRC

• TBD, at Arizona Public Service

• Chris Hope, Manager, Flight Technologies and Procedures Division at FAA

• Susanne Lloyd, Senior Manager at Constellation

• Julio Lara, Director, Division of Reactor Projects in Region III at NRC

+ Managing Uncertainty: The Role of Safety Margins and Performance Monitoring

• Sunil Weerakkody, Senior Technical Advisor on Probabilistic Risk Assessment, Division of Risk Assessment at NRC

• Matt Forsbacka, Director, Mission Assurance Standards and Capabilities Division at NASA

• Fernando Ferrante, Program Manager at EPRI

6 Diversity of perspectives and topics (cont.)

+ Developing and Maintaining RiskPart of Your Organizational Culture-Informed Decision Making as

• Mirela Gavrilas, Director of the Office of Nuclear Security and Incident Response at NRC

• Cheryl Gayheart, Director of Risk Informed Engineering & Safety Analysis at Southern Nuclear

• Homayoon Dezfuli, Risk Management Program Manager at NASA

• Mark Steinbicker, Acting Director of the Office of Safety Standards, Flight Standards Service at FAA

• Ryan Maitland, Superintending Inspector, Nuclear Safety Professional Lead of Fault Analysis at the Office for Nuclear Regulation

7 Diversity of perspectives and topics (cont.)

+ Risk informing Licensing Basis Events Across Operating, New and Advanced Reactors

• Prasad Kadambi, Chair of the special committee on Risk-informed, Performance-based Principles and Policy Committee at the American Nuclear Society

• Marty Stutzke, Senior Advisor for Probabilistic Risk Assessment, Division of Advanced Reactors and Non-Power Production and Utilization Facilities at NRC

• Chris Van Wert, Senior Advisor for Reactor Fuel, Division of Safety Systems at NRC

• Ben Holtzman, Program Advisor, New Reactors and Advanced Technology at NEI

+ Common Cause Failure Analysis of Digital Systems

• Samir Darbali, Electronics Engineer, Division of Engineering and Eternal Hazards at NRC

• TBD at EPRI

• Alan Campbell, Technical Advisor at NEI

• Han Bao, Nuclear Research & Development Scientist at the Light Water Reactor Sustainability Program

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9 Ri sk Assessment Process f or Topical Reports ( RAPTR)

10 Risk Informing Topical Report Reviews

+ Current TR review process is described in LIC-500, Rev. 9, "Topical Report Process," Jan 2022 (ADAMS Accession No. ML20247G279).

+ Consistent with LIC-500 Rev. 9, a sponsor can propose one of four review pathways:

• Standard - Highly complex new or revised TR - 2 years

• Compressed - Less complicated TR, minimal RAIs - 1 year

• Uncomplicated - Minor revision TR, no RAIs 12 months

• SE Confirmation - Revision which doesn't revise existing SE (vendor change) 6 month

11 Risk Informing Topical Report Reviews ( Cont.)

+ On February 16, 2023, the PWROG submitted via letter PWROG-22010- NP Risk Assessment Process for Review of Topical Reports (RAPTR) (ADAMS Accession Nos. ML23047A200 and ML23047A202).

+ PWROG's submittal recommended potential guidance that would generically determine the safety significance of future topical reports and to assign appropriate resources commensurate with that significance.

12 Risk Informing Topical Report Reviews (Cont.)

+ On July 6, 2023, staff held a public meeting (ADAMS Accession No. ML23186A120) to discuss the TR process and to gain additional insights on the proposal from the PWROG.

+ NRC believes it is premature to update the LIC-500 process currently.

+ NRC is open to continue to engage with industry and other interested parties in developing and aligning on a generic assessment process.

• Public meeting to provide detailed discussion on the examples previously submitted, or other examples, where a generic RIDM approach would provide regulatory certainty or resource savings

• This would include demonstrating the process with a specific industry issue

+ Once a process is developed, staff will explore enhancing regulatory processes that could leverage the generic assessment process where there is a clear cost-benefit.

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14 Seismic Re-Evaluation Under Process for Ongoing Assessment of Natural Hazard I nformation ( POANHI)

15 Current Status

+ Hazard and risk significance reunderway for multiple plants-evaluation complete or

• Risk significance screening uses thresholds identified in November 2022 public meeting

• Any plant modifications due to postare being considered-Fukushima seismic PRA results

• If necessary, licensee will be contacted for public meeting to discuss re-evaluation

+ Letter and hazard reports have started to be issued

• Latest letters address uncertainty about licensee actions

+ Public website for POANHI: https://www.nrc.gov/reactors/operating/ops -

experience/poanhi/seismic-activities.html

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17 Ri sk-I nfor mi ng Di gi tal I nstrumentati on and Control (DI&C)

18 Status of SECY on Risk-Informing DI&C C o mmon Cause Failure Eval uation

• S EC Y-22Potential Common-Cause Failures in- 0076 Expansion of Current Policy on Digital Instrumentationsupplement, ML22357A037) and Control Syste m s (with

• Commission approved staff proposal on May 25, 2023 (ML23145A176).

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Specific Directions to Staff in SRM-SECY-22-0076

• The staff should clarify in the implementing guidance that the new policy is independent of the licensing pathway selected by reactor licensees and applicants.

• Given the regulatory importance of this issue, the staff should complete the final implementing guidance within a year from the date of this Staff Requirements Memorandum.

Next Steps to Issue Final Guidance Within One Year

+ Revise the existing staff guidance in Branch Technical Position 7 -19 Revision 8 (ML20339A647) as opposed to creating new guidance documents such as Interim Staff Guidance or Regulatory Guides.

+ Provide opportunities for key stakeholders to review and comment (e.g., public meetings, ACRS meetings).

Some PRA Related Challenges

• The guidance must be usable with the PRA models whose quality meets RG 1.200 standards.

• Creating usable guidance considering the fact DI&C systems are not modeled in detail in PRAs.

• Creating usable guidance NOW, considering that DI&C failure probabilities (including software failure probability) may have high uncertainties.

Anti cipatory Planning fo r Digital I &C D ata Needs

Licensing + Po s t-Licensing Implementation of S EC Y +PRA Update to Ref l e c t As-Use Appropriate Surrogate Built and As-Operated Plant

to Estimate Risk Significance +Use Non-bounding of the Postulated CCF in Va l u e s fo r DI&C Failure Support of PRA-supported Probabilities to Reflect D3 assessment. as-built as-operated (Near-te rm) Plant. (Long-term)

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24 SPAR Model Updates

25 Updating & Benchmarking SPAR Models

Benchmarking against the licensees models allows the SPAR models to reflect the as-built, as-operated plants.

Increased use of risk insights highlights the need to maintain the plant-specific PRA tools to support licensing and inspection activities.

Differences due to outdated models could lead to additional time/resource needed during oversight or licensing.

Voluntarily provide PRA information to support INL and NRC updating & benchmarking of the SPAR models.

Contact Michelle Gonzalez (Michelle.Gonzalez@nrc.gov) and Kristy Bucholtz (Kristy.Bucholtz@nrc.gov)

SPAR Models Update FY2023 Status SPAR-DASH

Make risk information accessible to all NRC staff

Gather key risk results in an easy-to-use interactive dashboard

Remove barriers and support communication of risk insights

Support Be riskSMART and our path to becoming a modern, risk-informed regulator A ssess Plant-to-events & pl ant hazards comparison

Ranking risk Off-normal importance conditions

Periodic update

Sample results do not represent actual plant risk

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30 PRA Configuration Control (PCC)

Update

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

31 Project Milestones

Completed Obtained Issue Public Develop Enf./SDP Develop Tabletops Alignment with Report on strategy and long-term at facilities NRC Mgt. on Tabletops Regional Panel oversight process Dec 2022PCC Proposal Jun 2023 Guidance 2026 Mar 2023 (ML23136A565) Dec 2023

Developed Conduct public Develop Gather feedback Working Group meeting near-term from near-term recommendations Workshop with oversight oversight, update as for near-term Tabletop guidance necessary path forward sites/Industry (OpESS) 2024-2026 Feb/Jun 2023 Stakeholders Summer 2023 Mar 2023 Key Messages

We are listening to your feedback, and we recognize the unique challenges of this oversight framework.

PCC WG is recommending the use of an OpESS for current oversight of PCC.

OpESS provides maximum flexibility for regions and the cross regional panel process will ensure consistent application.

The PCC WG is currently developing the guidance associated with implementing the OpESS.

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

33 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

34 WGs Recommended Inspection Enhancement

• Near-term Recommendation: OpE Smart Sample (OpESS)

PROPOSED 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

• Resident Baseline: 71111 Primarily 71111.18 Plant Modifications along with possible options for,

• 71111.06, Flood Protection Measures,

• 71111.12, Maintenance Effectiveness,

• 71111.13, Maintenance Risk Assessments and Emergent Work Control,

• 71111.24, Testing and Maintenance of Equipment Important to Risk,

• 71151, Performance Indicator Verification,

• 71152, Problem Identification and Resolution (PI&R)

• Mid-term: OpESS w ill be revised as needed based upon feedback.

• Long-term: OpESS results w ill inform any future ROP updates.

35 What will the OpESS look like?

Graded balanced approach.

Balanced approach will ensure SFCP that inspectors should only review aspects from approved and implemented risk-informed 50.69 OpESS NFPA 805 initiatives.

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

OpESS Proposed Details

1. Verify processes are in place to maintain risk-informed decisions, (i.e., new information and data).

2. Verify processes are in place to ensure the PRA is maintained with the as-built as-operated plant.

3. Verify significant modifications to the plant screened for review and any needed updates to the PRA and the Model of Record.

• Guidance would be applied in 2-stages:

1. Forward-looking (future changes) and,

2. Past-looking (backward completed changes).

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

37 OpESS Proposed details (cont.)

• Inspections w hich w ould focus on completed changes (i.e., backw ard-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 w hich w ould focus on current in-progress changes (i.e., forward-looking):

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

1. 71111.18, Plant Modifications (primary),

2. 7 1111. 0 6, Flood Protection Measures,

3. 7 1111. 1 2, Maintenance Effectiveness,

4. 7 1111. 1 3, Maintenance Risk Assessments and Emergent Work Control,

5. 7 1111. 2 4, Testing and Maintenance of Equipment Important to Risk,

6. 71151, Performance Indicator Verification,

7. 71152, Problem Identification and Resolution (PI&R)

38 Near-term Actions - OpESS

Obtain and address Industry and Public Feedback (Ongoing)

Finalize OpESS guidance (Ongoing)

Internal Communication/Awareness (Ongoing)

• Training and Communication with Inspectors (Ongoing)

Enforcement/Significance Determination Process

• Initiate Cross Regional Panel Process (Complete)

• Develop Screening Guidance (Ongoing)

Future Planned Outreach Efforts

Continue to engage with public and industry or other Industry meetings/interactions.

Possible update during the next ROP Bi -Monthly.

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