ML18206A408

Comments from NEI on Rg 1.160 Draft Revision 4 for Endorsement of NUMARC 93-01, Rev 4f

ML18206A408
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/25/2018
From:	Vaughn S Nuclear Energy Institute
To:	May Ma Office of Administration
Agrawal A, NRR/DIRS, 415-8310
References
NRC-2018-0131
Download: ML18206A408 (3)

Text

STEPHEN J. VAUGHN Senior Project Manager, Risk and Technical Support 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 sjv@nei.org nei.org July 25, 2018 Ms. May Ma Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

NEI Comments on Draft Regulatory Guide (DG)-1336, Proposed Revision 4 to Regulatory Guide 1.160 [Docket ID - NRC-2018-0131]

Project Number: 689

Dear Ms. Ma:

The Nuclear Energy Institute (NEI)1, on behalf of our members, appreciates the opportunity to provide comments on DG-1336, Proposed Revision 4 to Regulatory Guide 1.1602. The proposed Revision 4 to RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants endorses Revision 4f of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, specifically the applicability of the Maintenance Rule (i.e., 10 CFR 50.65) to the use of licensees diverse and flexible coping strategies (FLEX) support guidelines (FSGs) in plant emergency operating procedures (EOPs).

Overall, the changes reflected in DG-1336 are appropriate and well-articulated. However, NEI did note an unexpected addition in Section 2.1 Use of Probabilistic Risk Assessments (page 17 of DG-1336.) The last sentence of Section 2.1 notes that RG 1.200 An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities is an acceptable approach to develop and maintain Probabilistic Risk Assessment (PRA) acceptability in support of risk-informed decision-making.

1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

2 ML18129A080, Draft Regulatory Guide (DG)-1336, Proposed Revision 4 to Regulatory Guide 1.160

Ms. May Ma July 25, 2018 Page 2 Adding RG 1.200 to the PRA section of RG 1.160 is a new position and should be deleted, as RG 1.200 addresses licensing applications and is not applicable for RG 1.160 activities. NEI recommends maintaining the current language in Revision 3 of RG 1.160 (page 7 under Section entitled Use of Probabilistic Risk Assessments) that states When a PRA is used in a licensees implementation of the maintenance rule, the technical adequacy of the base PRA should be sufficient to provide the needed confidence in the results being used in the decision. If the staff does not agree with removing the reference to RG 1.200 from the proposed Revision 4 to RG 1.160, then NEI requests a public meeting at the staffs earliest convenience to support a technical discussion in resolving the comment.

Please find the full list of comments in the attachment to this letter for consideration as the staff incorporates stakeholder feedback and continues the DG-1336 concurrence process.

If you have any questions or require additional information, please contact me at (202) 739-8163; sjv@nei.org.

Sincerely, Stephen J. Vaughn Attachment c: Mr. Michael King, NRR/DIRS, NRC Mr. Michael Franovich, NRR/DRA, NRC Mr. Michael Cheok, RES/DRA, NRC Ms. Ami Agrawal, NRR/DIRS/IRIB, NRC Mr. Thomas Hipschman, NRR/DIRS/IRIB, NRC Mr. Stephen Burton, RES/DE/RGGIB NRC Document Control Desk

ATTACHMENT l NEI Comments on DG-1336: Proposed Revision 4 to Regulatory Guide 1.160 Page Comment Recommendation 9 Editorial. There is a comma after EA Remove the comma after EA 12-049 and 12-049 and there should be a period. replace it with a period.

9 In the sentence Because the FSG Change essential to the EOPs to essential to equipment is not essential to the EOPs, the successful implementation of the EOP the phrase essential to the EOPs mitigating strategies should be clarified.

12 In Section 1, the phrase subject to Given that the proposed Revision 4 to RG 1.160 is the following exceptions and not taking any specific exceptions to Revision 4F clarifications is different than Revision of NUMARC 93-01, the term provisions should 3 to RG 1.160 which states subject to be maintained or condense the phrase provisions the following provisions and and clarifications to just clarifications.

clarifications. It isnt clear why the term exceptions is being used instead of the previously used term provisions.

17 In Section 2.1, the last sentence RG Remove the last sentence in section 2.1 regarding 1.200, An Approach for Determining RG 1.200 and maintain the Revision 3 to RG the Technical Adequacy of Probabilistic 1.160 language from the section Use of Risk Assessment results for Risk- Probabilistic Risk Assessments that states When Informed Activities, (Ref. 18) describes a PRA is used in a licensees implementation of an approach the NRC staff finds the maintenance rule, the technical adequacy of acceptable to develop and maintain PRA the base PRA should be sufficient to provide the acceptability in support of risk-informed needed confidence in the results being used in decision-making is a new position the decision.

compared to Revision 3 (and all previous Revisions) to RG 1.160.

24 Reference 18 is RG 1.200. As described Remove Reference 18 NRC, RG 1.200, An in the comment on page 17 and the Approach for Determining the Technical Adequacy associated recommendation, the of Probabilistic Risk Assessment results for Risk-addition of RG 1.200 as a PRA reference Informed Activities, Washington DC. from page in RG 1.160 is not warranted. 24.