ML18228A834
| ML18228A834 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/2018 |
| From: | Adrienne Brown, Mike Franovich, Michael Montecalvo, Sunil Weerakkody NRC/NRR/DRA |
| To: | |
| References | |
| Download: ML18228A834 (22) | |
Text
Joint BWROG/PWROGTechnical Committee MeetingsNRC Panel: August 16, 2018Mike Franovich, Director Division of Risk AssessmentSunil Weerakkody, Sr. Technical Advisor, Division of Risk AssessmentMike Montecalvo, Acting Branch Chief, Division of Risk AssessmentAdrienne Brown, Reliability and Risk Analyst Risk-Informed Decision Making (RIDM): Action PlanMike Franovich, Director Division of Risk Assessment 12 2 An Action Plan is Being Implemented to Improve Risk-Informed DecisionmakingEnhance the integration of risk information into the organization's decision making practices and processes to improve the technical basis for regulatory activities, increase efficiency, and improve effectivenessNRR RIDM MissionSECY Paper StrategiesStrategy IVAdvance Risk
-Informed InitiativesStrategy IIIEnhance Mandatory TrainingTasksPHASE 1Evaluate tasks to generate findings and recommendationsPHASE 2Implement recommendationsStrategy IEvaluate/Update GuidanceStrategy IIDevelop Graded ApproachCross-CuttingCommunicationStrategy VEnhance Communication 3
The Action Plan Supports Increased Use of Integrated Reviews and Safety and Risk Insights 4
Strategies to Optimize Regulatory Activities
- Broaden efforts to promote RIDM practices
- Increase FLEX regulatory credit
-correlate future plant modifications with FLEX to reduce other hazards risk (e.g., internal fires& floods)-showcase FLEX capabilities when NRC conducts onsite audits
-increase reviewers, inspectors, and managers awareness
- Focus communications and coordination
-Conduct joint NRC
-Industry workshops on lessons learned from 50.69 and TSTF-505 reviews
-Improve coordination and accuracy of forecasted LAR submittals
-Sequence risk related LARs:
- Consider submitting TSTF-505 prior to 50.69 or lower tier LARs (TSTF-505 program has a very high pedigree for PRA acceptability), or
- Couple TSTF
-505 and 50.69 LARs and reviews 5
New MethodsSunil Weerakkody Sr. Technical AdvisorDivision of Risk Assessment 12 6 7PRA Acceptability
-3 Elements
- All 3 elements have to work together to demonstrate PRA acceptabilityRegulatory Guide (RG) 1.200 provides NRC staff positionPeer Reviewto demonstrate conformance with PRA StandardPRAStandardto demonstrate conformance with staff positionPRA ACCEPTABILITY 8New Methods Are a Current Focus Area for NRC and Industry
- Ongoing focus on industry peer-review and the F&O closure process -ASME/ANS PRA Standard updates
-RG 1.200 update
-NEI 17-07 *A risk-informed oversight process will complement licensing activitiesand possibly new methods Crediting Mitigating Strategies in Regulatory ApplicationsMike MontecalvoActing, Branch ChiefDivision of Risk Assessment 12 9 Crediting Diverse and Flexible Coping Strategies (FLEX) 1 0*FLEX developed to meet the Commission's Orders after the Fukushima accident*FLEX can also be utilized for:
-Outages-Defense-in-Depth*The NRC wants to encourage safety enhancements
- Addressing ongoing challenges 1 1 Challenges to Crediting FLEX
- No Operational Experience (OpE) data-Needed to develop, and support, equipment reliability used in risk assessments
-Prior OpEcollection effort by EPRI abandoned
-Owner's Groups have taken lead
-Have committed to sharing draft and final results
- HRA methods for unique FLEX actions
-Current HRA methods not adequate for all FLEX actions
-Ongoing work in NRR and RES to address this challenge
-RES held an expert elicitation in April 2018
-EPRI Workshop in February 2018 1 2 FLEX OpE data expectations
- Commission's PRA policy statement states:
-"PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review."
- The data needs to be of comparable resolution to what the NRC publishes on its public website.
-Failures, Number of attempts (or hours), and number of components
- The data does notneed to identify individual plants, consistent with our current approach.
- The data should be of sufficient resolution to verify that any poolabilityassumptions are statistically sound.-Basis for pooling FLEX diesels from different vendors 1 3Path Forward on FLEX OpE data*Owner's Group Effort
-Draft report Fall 2018
-Publish report (1 stquarter 2019
)*NRC is looking forward to reviewing the report
- Possible Public Meeting
-Discuss the NRC's review of the report
-Discuss how RES will integrate this information into the current process
- NRC staff is looking forward to engaging the owner's groups on the FLEX OpEdata.
Lessons Learned: Recent Risk
-Informed LAR ReviewsAdrienne BrownReliability and Risk AnalystDivision of Risk Assessment 12 1 4 1 5Influx of Risk
-Informed Applications Requires Increased Coordination and Planning Between NRC and Industry 41 79 184 0 50100150200FY16FY17FY18Number of Licensing ActionsRisk-Informed Licensing Actions Received from FY16
-FY18Projected TMRENTTF R2.150.69MiscAOTTSTF-505, 4BGSI-191TSTF-411RI-ISIRI TSTSTF-425, 5BNFPA805ILRT 66 1 6High Quality Submittals to Streamline Efficient Staff ReviewsPRA Configuration and ControlImplementation (Oversight)PRA Acceptability
- PRA QualityUp-to-date full-scope PRA peer reviews
- Crediting Appendix X, consistent with staff letter of acceptance
- Incorporations of precedent from previous SEs
- Disposition of open F&O applicable to risk
-application 1 750.69: Risk Informed Categorization of Structures, Systems, and Components
- LAR review scope:-NRC staff reviews the quality of the PRA models used in the categorization process
-NRC approves categorization process
-NRC does not review categorization results, procedures, or alternative treatment during LAR review. These are subject to inspection
- 16 applications for 50.69 received
-6 in early stages of review; 3 withdrawn-One SE has been issued, several reviews approaching completion 1 8Insights from Initial 50.69 Reviews
- Deviations from endorsed guidance
-Categorization of passive SSCs
-Public meetings preferred to discuss generic industry topics/deviations prior to LAR submittal
- Public meetings to resolve generic topics related to seismic or fire (sites without seismic analysis or fire PRA)*Some LARs require more review hours due to scope of PRA (e.g., seismic, high winds)
- NRC review resources are challenged due to the large volume of applications
- License Condition for approval specifying modeled PRA hazards and non
-PRA methods Tornado Missile Risk Evaluator (TMRE)*Three pilot plant LARs using TMRE draft guide (NEI 17-02 draft Rev. 1)
-Plant audits and RAIs generated to pilots
-Pilot plant RAI responses also updating NEI 17 Staff positioned to complete safety evaluations (SEs) following receipt of licensee responses
-Post-pilot amendments could model pilot SEs in advance of NEI 17-02 endorsement
-Staff prepared to receive approximately 12 amendments in FY19 *13 of 13 EGM 15
-002 extension requests dispositioned between January and June 1 8 2 0 TSTF-505: Risk-Informed Technical Specification Completion Times
- Background
-TSTF-505 suspended (November 2016)
-Vogtle's License Amendment for RICT issued (August 2017
)*Vogtle was the "pilot" for changes needed to unsuspend TSTF-505-NRC staff modified TSTF-505 and the model application/SE
- No RICT for loss of function
- Enables licensing efforts to advance forward
- License Condition for use of new methods
- September/October target for revised TSTF model application and safety evaluation report NRC PANEL: QUESTIONS 2 1 2 2 Acronyms*ANS: American Nuclear Society*ASME: The American Society of Mechanical Engineers
- CDF: Core Damage Frequency
- CFR: Code of Federal Regulations
- DRA: Division of Risk Assessment
- EGM: Enforcement Guidance Memorandum*FLEX: Diverse and Flexible Coping Strategies
- F&O: Fact/Finding and Observation
- FY: Fiscal Year
- HRA: Human Reliability Analysis
- LAR: License Amendment Request
- NEI: Nuclear Energy Institute
- NFPA: National Fire Protection Association
- NOED: Notice of Enforcement Discretion
- NTTF: Near Term Task Force
- PM: Project Manager
- RG: Regulatory Guide*RI: Risk-Informed *RICT: Risk
-Informed Completion Time*RIDM: Risk
-Informed Decision
-Making*RISC: Risk-Informed Steering Committee*RITS: Risk-Informed Technical Specifications
- ROP: Reactor Oversight Process
- SE: Safety Evaluation
- SFCP: Surveillance Frequency Control Program*SR: Surveillance Requirement
- SSC: Structure, System, or Component*TMRE: Tornado Missile Risk Evaluator
- TS: Technical Specification
- TSTF: Technical Specification Task Force