ML19254A606

NRR E-mail Capture - (External_Sender) 09/10/2019 Public Meeting with NEI to Discuss Changes to a Proposed Lic Condition the Use of New PRA Methods Following the Issuance of a License Amendment to Utilize Risk-Informed TSs - NEI Comments

ML19254A606
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/10/2019
From:	Anderson V Nuclear Energy Institute
To:	Sunil Weerakkody NRC/NRR/DRA
References
Download: ML19254A606 (5)

Text

NRR-DRMAPEm Resource From: ANDERSON, Victoria <vka@nei.org>

Sent: Tuesday, September 10, 2019 2:24 PM To: Weerakkody, Sunil; Linthicum, Roy R.:(Exelon Nuclear)

Cc: Reisi Fard, Mehdi; Levine, Michael; Miller, Ed; Vasavada, Shilp; Rosenberg, Stacey; Dolan, Bradley Wicker (bwdolan@tva.gov); Mann, Brian; BONANNO, Jerry

Subject:

[External_Sender] RE: NRC comments on the content of the report Attachments: RevisednewmethodsTECHSPEC-public-meeting VKA markup.docx Our markup of the proposed words is attached.

From: Weerakkody, Sunil <Sunil.Weerakkody@nrc.gov>

Sent: Tuesday, September 10, 2019 12:25 PM To: ANDERSON, Victoria <vka@nei.org>; Linthicum, Roy R.:(Exelon Nuclear) <roy.linthicum@exeloncorp.com>

Cc: Reisi Fard, Mehdi <Mehdi.Reisifard@nrc.gov>; Levine, Michael <Michael.Levine@nrc.gov>; Miller, Ed

<Ed.Miller@nrc.gov>; Vasavada, Shilp <Shilp.Vasavada@nrc.gov>; Rosenberg, Stacey <Stacey.Rosenberg@nrc.gov>

Subject:

[EXTERNAL] NRC comments on the content of the report Victoria & Roy, I have attached a draft for our discussion today.

Please note that our proposed comments and the discussion today on the tech spec do not constitute an implicit or an explicit approval of NEI proposal. That decision will be made by the NRR Office Director or his assignee after a formal legal review of your proposal.

Sunil Weerakkody Senior Technical Advisor, Probabilistic Safety Assessment Division of Risk Assessment Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Tel: 301-415-2870 This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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Hearing Identifier: NRR_DRMA Email Number: 194 Mail Envelope Properties (0fc33f99cdfb45668c1e54b35ca6f962)

Subject:

[External_Sender] RE: NRC comments on the content of the report Sent Date: 9/10/2019 2:24:17 PM Received Date: 9/10/2019 2:24:41 PM From: ANDERSON, Victoria Created By: vka@nei.org Recipients:

"Reisi Fard, Mehdi" <Mehdi.Reisifard@nrc.gov>

Tracking Status: None "Levine, Michael" <Michael.Levine@nrc.gov>

Tracking Status: None "Miller, Ed" <Ed.Miller@nrc.gov>

Tracking Status: None "Vasavada, Shilp" <Shilp.Vasavada@nrc.gov>

Tracking Status: None "Rosenberg, Stacey" <Stacey.Rosenberg@nrc.gov>

Tracking Status: None "Dolan, Bradley Wicker (bwdolan@tva.gov)" <bwdolan@tva.gov>

Tracking Status: None "Mann, Brian" <brian.mann@excelservices.com>

Tracking Status: None "BONANNO, Jerry" <jxb@nei.org>

Tracking Status: None "Weerakkody, Sunil" <Sunil.Weerakkody@nrc.gov>

Tracking Status: None "Linthicum, Roy R.:(Exelon Nuclear)" <roy.linthicum@exeloncorp.com>

Tracking Status: None Post Office: nei.org Files Size Date & Time MESSAGE 2244 9/10/2019 2:24:41 PM RevisednewmethodsTECHSPEC-public-meeting VKA markup.docx 29542 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

From: Weerakkody, Sunil Sent: Friday, August 30, 2019 5:35 AM To: Weaver, Tonna <Tonna.Weaver@nrc.gov>

Subject:

Please capture this email from NEI into public ADAMS and send me the ML#- Thank you!

From: ANDERSON, Victoria <vka@nei.org>

Sent: Thursday, August 22, 2019 6:11 PM To: Weerakkody, Sunil <Sunil.Weerakkody@nrc.gov>

Subject:

[External_Sender] RE: urgent request

e. A RICT must be calculated using the following PRA and non-PRA approaches approved by the NRC, including [list specific PRA and non-PRA approaches used for fire and seismic analysis (e.g., Fire PRA and Seismic Margins Analysis)]. Changes to these PRA and non-PRA approaches require prior NRC approval. The PRA maintenance and upgrade process will validate that other changes to the PRA models used in the RICT program, including changes involving newly-developed methods, follow [ [ASME/ANS RA-Sa-2009, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications," Regulatory Guide 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, and NEI 17-07, Revision 2, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard] OR [Regulatory Guide 1.200, Revision 3, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.] ] {RG 1.200, Rev. 3, when issued, with incorporate the other guidance by reference.}

f. A report shall be submitted in accordance with Specification [5.6.X].

following each PRA upgrade involving a newly-developed PRA method that has not been previously reported to the NRC for a RICT program and the associated peer review.

[5.6.X Probabilistic Risk Assessment (PRA) Upgrade Report A report shall be submitted following each PRA upgrade involving a newly-developed PRA method that has not been previously reported to the NRC for a RICT program and the associated peer review in accordance with Specification

[5.5.18]. The report shall describe the scope of the upgrade, including (1) the PRA models upgraded and newly developed methods used, (2) the peer review

and finding closure reports available to the NRC for oversight and inspection activities, (3) the number of, and characterization of, the open findings remaining in the upgraded model, and (4) identification of any RICTs of less than 30 days Formatted: Font: (Default) +Body (Calibri) calculated to change by more than 50% for the zero-maintenance configuration .] (3) Formatted: Font: (Default) +Body (Calibri)

Confirmation that there are no open F&Os from the newly-developed method Commented [AV1]: This would be duplicative if RG 1.200 review(3), and any open findingsF&Os from the peer-review of implementation, (44) R3 is followed, as the latest revision of NEI 17-07 calls for all changes to key assumptions related to the newly developed method or its findings on newly developed methods to be closed prior to use implementation, (5) a summary of how supporting requirements are met, and qualifications of peer-reviewers of the newly-developed method, if the newly- Formatted: Font: (Default) +Body (Calibri) developed method report submitted by the method developer does not provide that Formatted: Font: (Default) +Body (Calibri) information. Formatted: Font: (Default) +Body (Calibri)

Formatted: Font: (Default) +Body (Calibri)

Formatted: Font: (Default) +Body (Calibri)

From: Weerakkody, Sunil <Sunil.Weerakkody@nrc.gov> Formatted: Font: (Default) +Body (Calibri)

Sent: Thursday, August 22, 2019 5:34 PM Commented [AV2]: This information will be available in To: ANDERSON, Victoria <vka@nei.org> the reports made available to the NRC staff and would be duplicative.

Subject:

[EXTERNAL] urgent request Importance: High Formatted: Font: (Default) +Body (Calibri)

Victoria, I want to try an submit my recommendation to legal before I leave tomorrow to Vienna. If you could send me a revised version of Tech Spec that addresses our feedback (except the items that will be in the reports for which you need our feedback),

that would be great. It does not have to be the final version. The key attribute I need to communicate to OGC is that the proposed tech spec contains (a) clear enforceable requirements for reviewing new methods, and (b) there is clear definition of what constitute a newly-developed method. Feel free to refer to Rev. 3 of RG 1.200 and NEI 17-07 as you see fit.

Thank you!

Sunil Weerakkody Senior Technical Advisor, Probabilistic Safety Assessment Division of Risk Assessment Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Tel: 301-415-2870 This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure:

To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this

communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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