ML22292A274

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NRC - Trends and PRA Config Control
ML22292A274
Person / Time
Issue date: 10/19/2022
From: Antonios Zoulis
NRC/NRR/DRA/APOB
To:
References
Download: ML22292A274 (16)


Text

PRA Counterpart Meeting October 2022

Updating &

Benchmarking SPAR Models Benchmarking against the licensees models allows the SPAR models to reflect the as-built, as-operated plants Increased use of risk insights highlights the need to maintain the plant-specific PRA tools to support licensing and inspection activities Differences due to outdated models could lead to additional time/resource needed during oversight or licensing Voluntarily provide PRA information to support INL and NRC updating of the SPAR models Contact Selim Sancaktar (Selim.Sancaktar@nrc.gov) or Ching Ng (Ching.Ng@nrc.gov)

3 Trends in ROP Since the start of the ROP, the NRC has issued approximately 17 greater-than-Green (GTG) or potentially GTGs on average per calendar year. Since 2018, the yearly average is approximately 4 potentially GTGs.

With this low number of potentially GTGs, it is not possible to draw any statistically significant trends.

The distribution across ROP cornerstones is in line with the historical distribution (e.g., approx. 50% in mitigating systems).

NRC staff are currently reviewing SDP timeliness as part of the ROP self-assessment process. See ML22269A480 for latest presentation at ROP public meeting on Sept. 28.

4 PRA CONFIGURATION CONTROL

5 Key Messages

  • The existing oversight process is adequate to ensure implementation of programs informed by PRA models.
  • However, we believe that there is a current gap in the oversight of PRA Configuration Control programs.
  • A balanced approach of focused inspections/safety enhancements within the existing ROP baseline inspection program of PRA changes and upgrades are being proposed to monitor appropriate implementation of configuration control programs for licensee PRA models that support risk-informed decision-making.

6 Key Messages (Cont.)

  • PRA Configuration Control framework will be informed and developed by the NRC working group recommendations, based on the information gathering and guidance development efforts, as well as with industry and the public through multiple public meetings.
  • Four out of eight tabletops completed:

- To date, based on a limited review, NRC staff have not identified any significant findings on how licensees are implementing their programs

- Based on the team's findings and observations of all eight tabletops, the team will propose recommendations to enhance oversight activities for approval

- The approach we are taking in addressing this initiative demonstrates our commitment to our principles of good regulation of openness.

7 Preliminary Lessons Learned

-Licensee: Focus on PRA Configuration Control rather than PRA Acceptability or re-certification of hazard group models via these tabletops and future inspections.

-Licensee: Sampling strategy recommendations.

7

8 Preliminary Assessment & Lessons Learned

  • PRA Configuration Control Program

- Appears to meet PRA Consensus Standard.

- Vulnerabilities identified in documentation and management of plant changes tracking databases. Knowledge based program.

  • Internal lessons include:

- Understand how the program works early.

- Maintain focus on PRA Configuration Control implementation.

8

9 Tabletop Effort Schedule

  • Future schedule:

- November 7 - 10, 2022 (SFCP, 50.69)

- November 14 - 17, 2022 (SFCP, NFPA 805)

- December 5 - 8, 2022 (SFCP, RICT, 50.69)

- December 5 - 8, 2022 (SFCP, RICT)

10 High-Level Plan ROP Change Control Process Conduct Tabletops Finalize Information Gathering Needs Refine guidance and share PRA Configuration Control Framework recommendations for feedback

11 Conducted 2 public meetings February &

April 2022 Identify and select eight facilities for table-tops/

site visits May 2022 Begin table-tops/site visits at facilities July 2022 Complete assessment of information gathered via site visits and guidance development effort December 2022 Brief NRR management on final recommendations of effort March 2023 Discuss findings at ROP monthly public meeting April 2023 Discuss any feedback at ROP Monthly public meeting May 2023 Revise Tier 2 inspection guidance December 2023 Overall Plan & Path Forward Enter ROP change control process February 2023

12 TRENDS IN LICENSING

Staff Continues Review of Risk-Informed Programs 10 CFR 50.69 Risk-Informed Categorization TSTF-505 Risk-Informed Completion Times Completed 42.59%

Under Review 1.85%

Projected 12.96%

Remaining 42.59%

Completed 38%

Under Review 8%

Projected 15%

Remaining 39%

14 TSTF-591, Revise Risk Informed Completion Time (RICT)

Program

- requirements for the peer review of newly developed methods (NDMs)

- process for determining whether a change to a PRA is classified as maintenance or upgrade

- definitions related to NDMs, PRA maintenance, and PRA upgrade

- Outlined in NEI 17-07, Rev. 2, Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard and PWROG-19027-NP, Rev. 2, Newly Developed Method Requirements and Peer Review,

- Proposes submittal of a report to inform the NRC of the use of newly developed PRA methods to calculate a RICT

15 Guidance on FLEX Credit in Risk-informed Applications May 2017 (ML17031A269) NRC staff memo assessed the use of guidance in NEI 16-06 for crediting mitigating strategies (FLEX) in PRAs used to support risk-informed applications.

The NRC staffs 2017 assessment certain elements of NEI 16-06 lacked sufficient technical justification outlined 13 conclusions where improved industry guidance was needed May 2022 NRC issued updated Assessment of Guidance for Crediting FLEX in RIDM (ML22014A084) to reflect new guidance

- EPRI 3002013018, Human Reliability Analysis (HRA) for Diverse and Flexible Mitigation Strategies (FLEX) and Use of Portable Equipment and two knowledge-based articles (KBAs)

- PWROG-18043 FLEX Equipment Data Collection and Analysis Its use expected to reduce staff questions

16 Questions?