ML18130A744

NRR E-mail Capture - 05/10/18 Public Meeting with the NEI to Discuss NRC Staff Observations of Licensees Performing F&O Closures in Accordance with Appendix X to NEI 05-04, NEI 07-12, and NEI 12-13 - NRC Staff Slides

ML18130A744
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Issue date:	05/10/2018
From:	Ed Miller Special Projects and Process Branch
To:	Ed Miller Special Projects and Process Branch
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Download: ML18130A744 (17)

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NRR-DMPSPEm Resource From: Miller, Ed Sent: Thursday, May 10, 2018 12:17 PM To: Miller, Ed

Subject:

NRC staff slides for Appendix X Meeting Attachments: May 10 F&O guidance NRC slides.pptx; Legacy Peer Reviews rev 4.pptx Attached are the NRC staff slides for the May 10, 2018, public meeting to discuss the Appendix X F&O closure process.

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Hearing Identifier: NRR_DMPS Email Number: 362 Mail Envelope Properties (DM5PR0901MB23929D40BA35219FD750A38DE9980)

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NRC staff slides for Appendix X Meeting Sent Date: 5/10/2018 12:17:19 PM Received Date: 5/10/2018 12:17:22 PM From: Miller, Ed Created By: Ed.Miller@nrc.gov Recipients:

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

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F&O Closure Process Guidance Stephen Dinsmore Senior Risk and Reliability Analyst NRR/DRA/APLA May 10, 2018

Appendix X Assessment of Upgrade

• Licensee to provide a written assessment and justification of whether each finding constitutes a PRA upgrade, maintenance update

• IA Team to provide For each F&O, assessment of whether the resolution was determined to be a PRA upgrade [or] maintenance update 2

Appendix X CC II Confirmation and New Method Reviews

• the team will review the SR to ensure that the aspects of the underlying SR that were previously not met, or met at CCI, are now met, or met at CCII.

• independent assessment team notes the incorporation of a new method into a licensees PRA, they will not review the new method itself, and will not close relevant findings associated with the new method 3

DOCUMENTATION Nothing so sharpens the thought process as writing down one's arguments. Weaknesses overlooked in oral discussion become painfully obvious on the written page.

Admiral Hyman G. Rickover 4

Full-Scope Peer Reviews Pre NEI 00-02 Michael Levine Risk and Reliability Analyst NRR/DRA/APLA May 10, 2018

Background

• NEI 00-02

- Rev A3, March 2000

- Industry guidance for conducting PRA peer reviews

- Endorsed by NRC, with clarifications, in RG 1.200 in 2004

- Guidance material was adapted from the review process developed and used by BWROG, which was provided to the industry by BWROG through the NEI Risk Based Applications Task Force (RBATF)

- Joint endeavor between WOG and the B&WOG through the NEI RBATF, with input from the CEOG and the BWROG.

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Background (continued)

• RG 1.200

- Rev 2, March 2009

- Endorsed NEI 00-02, Rev 1, (as historical) with clarifications

- Provides mapping between NEI 00-02 elements and ASME/ANS SRs (RA-Sb-2005), however, not a 1-to-1 correlation

- Provides correlation between NEI 00-02 grade and ASME/ANS Std.

capability category.

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Issues

• Some licensees last full-scope PRA peer reviews were done prior to NEI 00-02

• Closure of F&Os from pre NEI 00-02 peer reviews not addressed in App X

• Peer reviews were performed using different owners group (WOG, CEOG, etc.) standards.

- These standards were not endorsed by NRC

- No NRC endorsed mapping between these standards and NEI 00-02 or ASME/ANS Std.

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Potential Problems

• Potential deficiencies in PRA models that were not identified because of the aggregate of subtle differences between early standards, NEI 00-02, and the ASM/ANS standard.

• Some licensee PRA models may not have had an independent review against an endorsed standard; only self-assessments for gaps between early standards and NEI 00-02 or ASME/ANS standard (for which there is no endorsed mapping).

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Potential Problems Example

• Plant X submitted a risk-informed amendment request which included resolutions to open F&Os from its full-scope peer review. The peer review was performed against a pre-NEI 00-02 standard, however, the licensee mapped the SRs tied to each F&O to the current ASME/ANS standard using the endorsed mapping in RG 1.200 assuming that NEI 00-02 was sufficiently similar to the early standard used in the peer review.

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Potential Problems Example (cont.)

• The standard used in the peer review is not sufficiently similar to NEI 00-02. As a result, many of the F&O resolutions were not applicable to the mapped SRs.

• This is problematic because:

- Licensee has not had an independent full-scope peer review against an endorsed standard

- The integrity of the licensees F&O closure review is compromised because the resolutions were reviewed against the wrong SRs 7

CEOG vs NEI 00-02

• WCAP-1593 (not endorsed by NRC) tries to correlate CEOG grading to NEI 00-02, however, CEOG grading is very ambiguous and not really equivalent to NEI 00-02 grading 8

CEOG vs NEI 00-02 9

Path Forward A. Address pre-NEI 00-02 peer review issues via RAI process.

- Very labor intensive and would significantly delay applications.

B. Require most recent full-scope peer review to be at least in accordance with NEI 00-02 C. Rescind endorsement of NEI 00-02 and require most recent full-scope peer review against ASME/ANS standard (i.e., no more gap assessment between NEI 00-02 and ASME/ANS std. allowed) 10

Questions

?

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