ML19253D706
| ML19253D706 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/2019 |
| From: | Alexander Schwab NRC/NRR/DRA/APOB |
| To: | Antonios Zoulis NRC/NRR/DRA/APOB |
| Alexander Schwab | |
| Shared Package | |
| ML19253E543 | List: |
| References | |
| Download: ML19253D706 (5) | |
Text
October 26, 2019 MEMORANDUM TO: Antonios Zoulis, Chief PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM: Alexander Schwab, Reliability and Risk Analyst /RA/
PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF AUGUST 22, 2019 PUBLIC MEETING TO CONTINUE DISCUSSIONS BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND INDUSTRY RISK-INFORMED STEERING COMMITTEES On August 22, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting between the NRC and industry Risk Informed Steering Committees (RISCs).
The meeting notice and presentations used to facilitate discussion are available in the Agencywide Documents Access and Management System, at Accession Number ML19253E543. The list of meeting participants is provided as an enclosure to this document.
Staff did not receive any public meeting feedback forms as a result of this meeting.
Both the NRC and industry provided opening remarks and discussed the agenda. During the meeting the staff provided status updates on Risk-Informed Licensing, Fire Probabilistic Risk Assessment (PRA) Realism, High Energy Arc Faults (HEAFs), Treatment of FLEX in Risk Informed Decision Making and Human Reliability Analysis (HRA), and New PRA Methods.
Details on each of these topics are described below.
Opening Remarks The NRC opened by remarking that collectively there has been significant progress on risk-informed decisionmaking efforts, such as closing out Generic Safety Issue-191, and that the staff was using the best tools available. NRC management also mentioned that the agenda was mostly focused on PRA topics, but that everyone should keep in mind that risk-informed decision making is an integrated approach using risk (including but not limited to PRA) and deterministic considerations. The NRC also remarked that this was a good time to try and broaden the discussion on being more risk-informed from predominately an operating reactor centric focus to more of an agency wide focus. Industry agreed good progress is being made, and was open to include other initiatives to deepen the risk mindset in industry and NRC activities.
CONTACT: Alexander Schwab, NRR/DRA 301-415-8539
A. Zoulis Risk Informed Licensing The NRC began the discussion on this topic by reminding everyone that when the NRC approves a 50.69 (Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors) or Technical Specification Task Force (TSTF) 505 (Provide Risk Informed Extended Completion Times - Initiative 4B) application, it is approving the licensees program and not the licensees PRA model. The NRC then stated that there have recently been fewer risk-informed applications received from licensees than expected, and that such a lull in work, if it continues, could cause some NRC resources to be reallocated away from risk-informed applications.
The NRC then discussed the current status of 50.69 and TSTF 505 applications. Industry mentioned that they could take on creating more guidance to address treatment of uncertainty instead of relying on the NRC updating NUREG-1855 (Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making). The NRC replied they were open to further discussion on this topic.
The NRC also stated that there would be a public meeting on Tornado Missile Risk Evaluator applications on September 10th, 2019.
Fire Probabilistic Risk Assessment Realism The NRC went through the associated milestones. Industry remarked that there were lessons learned regarding coordination between NRC Office of Research and Electric Power Research Institute (EPRI) on resource alignment. The NRC agreed.
Industry also asked if they could incorporate Fire PRA guidance documents (such as NUREG-1922, Supplement 2, NUREG-2178, Volume 2, NUREG-2230, and NUREG-2232) into their Fire Protection programs once EPRI published them, instead of waiting for the NRC to publish them officially as NUREGs. The NRC replied that they believed the industry could, but that the NRC would take an action to check and would get back to industry.
HEAFs (High Energy Arc Faults)
The NRC remarked that there were several not yet scheduled public meetings on the topic upcoming, and that the scheduling and planning for testing was ongoing.
Crediting FLEX in Risk-Informed Decision Making and HRA The NRC reiterated that they are currently crediting FLEX in a variety in of regulatory decisions, and that they are in the process of incorporating FLEX into their SPAR models.
The NRC also discussed their plans to audit the FLEX data the industry is collecting and the industrys method for deriving equipment failure probabilities from the data within the next few weeks. Industry cautioned that the NRC shouldnt be too influenced by the early equipment failure probabilities as the industry believes they are in the early portion of the bathtub curve as the industry figures out how to optimize maintenance of the FLEX equipment.
Industry also reiterated their concerns regarding how the NRC is merging Inspection Manual Chapter (IMC) 0609 Appendix O (Inspection Manual Chapter Significance Determination Process (SDP) for Mitigating Strategies and Spent Fuel Pool Instrumentation) into IMC 0609
A. Zoulis Appendix A (SDP for Findings At-Power). From the industrys prospective the NRC is not simply merging the two appendices but instead the NRC is changing the regulatory threshold for FLEX. They stated this could also create extra work for both the NRC and industry. It was mentioned that this would be discussed at the next monthly Reactor Oversight Process public meeting to be held on August 28th, 2019.
The NRC also brought up their benchmarking of the Integrated Human Event Analysis System (IDHEAS) Event and Condition Assessment (ECA) HRA method. This will be used to calculate FLEX Human Error Probabilities (HEPs). The NRC also stated that while the initial goal of the IDHEAS ECA method is to calculate FLEX and other ex-control room actions HEPs, the end goal is to replace the SPAR-H with IDHEAS ECA for all HEP calculations. The industry expressed that the NRC staff responsible for this benchmarking project should make sure to have open communications with operators at plants, so the project team would be aware of the actual plant conditions and operator training. The NRC agreed, stating that is how they have been proceeding up to this point and that they will continue to do so.
New PRA Methods Approval Process The NRC started off stating that this PRA new methods approval process would be an alternate approval process and that it would leverage the PRA peer review process delineated in NEI 17-07 (Performance of PRA Peer Reviews using the American Society of Mechanical Engineers /
American Nuclear Society PRA Standard). The NRC stated that if they were able to obtain agreement across the agency (including an NLO determination (No Legal Objection) from the Office of General Counsel), the plan is to endorse NEI 17-07, through an update to Reg Guide 1.200 (An Approach for Determining the Technical Adequacy of PRA Results for Risk-Informed Activities).
Closing Remarks The public was given an opportunity to ask questions or make comments, and no one chose to do so. The NRC RISC chair then thanked the participants and closed the meeting.
Enclosure:
List of Meeting Attendees
ML19253D706 *via email NRR-106 OFFICE NRR/DRA/APOB NRR/DRA/APOB: BC*
NAME ASchwab AZoulis DATE 9/26/2019 9/9/2019
LIST OF MEETING ATTENDEES Name Organization Jana Bergman Curtiss-Wright Roy Linthicum PWROG Jeff Stone Exelon George Gellrich Exelon Tom Basso NEI Victoria Anderson NEI Russ Felts NRC Jamie Heisserer NRC Stephen Grier NEI Matt Humberstone NRC Mike Cheok NRC Antonios Zoulis NRC Kelli Voelsing EPRI Mark Woodby EPRI Andrea Veil NRC Mark Lombard NRC Jonathan Evans NRC Mark Thaggard NRC Doug True NEI Bob Bement APS/Palo Verde Sunil Weerakkody NRC Mike Franovich NRC Ho Nieh NRC Mirela Gavrilas NRC Robert Lewis* NMSS Tim Sande* Enercon Joel Munday* NRC Brenden Overton* Nuscale John Hughey* NRC Alan Jelalian* EPM, Inc.
Mike OKeefe* Certrec Corporation
- Participated by teleconference Enclosure