ML20209A418

NEI - Treatment of FLEX in Risk-Informed Licensing Applications by Nuclear Energy Institute - July 29, 2020 FLEX Presentation

ML20209A418
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/27/2020
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Poole J, NRR/DORL/LPLI, 301-415-2048
References
Download: ML20209A418 (7)

Text

Treatment of FLEX in Risk-Informed Licensing Applications

Introduction

- RG 1.200 provides the NRCs regulatory position relative to PRA technical adequacy for risk-informed licensing applications

• Includes those used for integration of FLEX equipment into licensee PRAs.

- 2017 NRC memo outlined position on NEI 16-08

• Detailed departures of NEI 16-08 from RG 1.200

• Was anticipated since NEI 16-08 was developed for a wide range of potential approaches, including activities other than licensing applications.

©2020 Nuclear Energy Institute 2

Introduction

- Even when using approaches to integrating FLEX into PRAs that align with RG 1.200, licensees have still run into difficulties

• Limerick TSTF-505: 19-part RAI on FLEX equipment

- Several other plants receiving RAIs of similar scope

• Hope Creek 50.69: RAI requesting plant-specific operating experience and test results for FLEX

- RAIs of this nature are not isolated

- Meeting objective: Determine licensee actions that can best address these issues proactively in LARs ©2020 Nuclear Energy Institute 3

Generic FLEX RAI Topics

- What is the purpose of RAI questions regarding whether or not FLEX equipment or actions are credited?

- What is the purpose of RAI questions on consistency with ASME/ANS PRA Standard, as this is addressed for the full PRA, including FLEX?

- Will the PWROG FLEX data report issuance will make questions regarding plant-specific data obsolete?

©2020 Nuclear Energy Institute 4

Generic FLEX RAI Topics

- What is the purpose of RAI questions that specifically inquire about the HRA process for FLEX?

- What is the purpose of RAI questions regarding whether or not FLEX constitutes and upgrade?

- What is the purpose of RAI questions related sensitivity studies specifically for FLEX items?

©2020 Nuclear Energy Institute 5

Additional Discussion Topics

- Licensees have also received RAIs relative to not crediting FLEX

- Unclear if these questions are necessary to write the SE

- A new peer review is not necessarily needed after incorporation of FLEX into a licensees PRA

©2020 Nuclear Energy Institute 6

Path Forward

- Work towards regulatory stability for treatment of FLEX in risk-informed licensing applications

- Establish well-understood use of RG 1.200 for addressing use of FLEX in licensee PRAs supporting risk-informed licensing applications

- Develop generic language for LARs to reduce effort expended on RAIs

©2020 Nuclear Energy Institute 7