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{{Adams
{{Adams
| number = ML14114A506
| number = ML20293A488
| issue date = 04/14/2014
| issue date = 11/05/2020
| title = Enhancement Working Group Proposed Problem Statement
| title = Rev 3 - ACRS Fc Briefing-draft-final-no-notes
| author name =  
| author name = Gilbertson A, Vasavada S, Weerakkody S
| author affiliation = Nuclear Energy Institute (NEI)
| author affiliation = NRC/NRR/DRA, NRC/RES/DRA/PRB
| addressee name =  
| addressee name =  
| addressee affiliation = NRC/NRR
| addressee affiliation =  
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = Montecalvo M, NRR/DRA, 415-1678
| contact person = Weerakkody S
| case reference number = RG 1.200
| document type = Slides and Viewgraphs
| document type = Regulatory Guide
| page count = 26
| page count = 2
}}
}}
{{#Wiki_filter:Regulatory Guide 1.200 Enhancement Working Group Proposed Problem Statement
{{#Wiki_filter:Regulatory Guide 1.200, Revision 3 Briefing for the Advisory Committee on Reactor Safeguards Full Committee Anders Gilbertson Technical Lead / Reliability and Risk Analyst RES/DRA/PRB
Anders.Gilbertson@nrc.gov November 5, 2020
Shilp Vasavada Senior Reliability and Risk Analyst NRR/DRA/APLC
Shilp.Vasavada@nrc.gov Sunil Weerakkody Senior Level Advisor NRR/DRA
Sunil.Weerakkody@nrc.gov


Issue Description
Overview
* Purpose
* Background
* Changes incorporated into Revision 3
* ACRS Subcommittee members feedback
* Primary regulatory driver for Revision 3
* Resolution of public comments on DG-1362
* Path forward
2 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


The industry and NRC have long-term difficulties associated with communicating information on PRA
Purpose To brief the ACRS Full Committee and solicit feedback on the staffs resolution of public comments on the staffs proposed revision 3 to Regulatory Guide (RG) 1.200 (i.e., DG-1362*)
technical adequacy, including inability to reach a mutual understanding of expectations for documentation of this information in licensing applications and disagreements regarding the appropriate level of staff review of the PRA supporting the licensing application. The NRCs regulatory position on PRA technical adequacy for licensing applications is documented in RG 1.200; however, the staff has expressed concern with the sufficiency of this process for new models and methods, while the industry has encountered frustration when attempting to pursue innovative approaches, and when being faced with additional staff questions despite preparing licensing applications and responses to requests for additional information in accordance with RG 1.200. To address these problems, the process currently laid out in RG 1.200 needs enhancement to realize the full value of PRA standards and peer reviews, and to reduce associated burden to licensees and the NRC.
* Available in the Agencywide Document Access and Management System (ADAMS) under accession No. ML19308B636
3 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


Major Objectives
Background
* RG 1.200 provides an approach for determining the technical acceptability of a base probabilistic risk assessment (PRA) model for use in regulatory decisionmaking for light-water reactors (LWRs)
* PRA acceptability is determined with respect to the following aspects of the base PRA:
- Scope
- Level of detail
- Conformance to consensus PRA standard technical elements (i.e., technical robustness)
- Plant representation
4 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


Develop a consensus process for making new PRA methods available for regulatory application
Background - PRA Acceptability
5 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Each element depends on the other in order to demonstrate PRA acceptability This paradigm obviates the need for an in- depth staff review of the base PRA model Draft Final


There is a need to have an agreed upon process that ensures that the methods used have received an appropriate level of technical scrutiny by experts before being used and that the peer review teams have the appropriate expertise to review the application of these methods. An important aspect of this is the process by which methods are accepted for use.  At present there is not a clear understanding of what constitutes a "consensus method,  and so all "new methods" are subjected to a detailed review by the NRC when used in licensing applications. A more graded approach is needed, based on the pedigree of the method.
Background - PRA Acceptability (cont)
6 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Risk-Informed Inservice Inspection
50.69 SSC Categorization TSTF-425, Surveillance Frequency Control Prgm.


1. Existing methods that are commonly used for US nuclear power plant PRAs
NFPA-805, Risk-Informed Fire Protection RITS-4b, Risk-Informed Completion Times Required scope, level of detail, technical robustness, and plant representation
2. Existing methods that are commonly used for nuclear power plant PRAs in other countries, but not commonly in the US
* Greater reliance on PRA
3. Existing methods that are commonly used in other industries, and have a corollary in nuclear power plants, but have not commonly been used in nuclear power plant PRAs
* More flexibility for licensee
4. New methods developed by or in cooperation with NRC or other US or international regulatory body
* More complex staff review Draft Final
5. New methods developed by research organizations independently of NRC, regardless of origin
6. New methods developed and implemented within a specific PRA submittal


Each of these methods bins needs to be defined as to the attributes that make it fall into a specific category, and then the conditions under which they can be used in US NPP PRAs ("criteria for appropriateness for use") needs to be established, and a simple vetting process for determining that the method meets the criteria. Where necessary, a peer-review process for determining appropriateness would be established.  It is expected this would only be required for 5 and 6.
Changes incorporated into RG 1.200,
Revision 3
* Endorses new industry documents:
- NEI 17-07, Revision 2 (ML19241A615)
* Consolidates predecessor industry PRA peer review guidance for different hazard groups
- PWROG-19027-NP, Revision 2 (ML20213C660)
* Includes requirements for determining acceptability of newly developed methods (NDMs) and necessary submittal documentation
* Includes process for differentiating between PRA
maintenance and a PRA upgrade
- ASME/ANS RA-S Case 1 (i.e., the seismic code case)
7 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


The additional problem is a current lack of assurance that the peer review team members are appropriate for the review.  To assure adequate peer review of the PRA, a documented set of criteria must be available to assure that the review team has the necessary expertise to perform the peer review (i.e., that the reviewers would be qualified to perform the analytical tasks that they are
Changes incorporated into RG 1.200,
Revision 3 (cont)
* Provides a new glossary of terms
- Some terms adopted directly from PWROG-
19027-NP
* Provides descriptions of hazards to be considered in the development of a PRA
RG 1.200, Revision 3, retains the staff endorsement of ASME/ANS RA-Sa-2009
8 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


reviewing).  This requires a "generic" set of criteria applicable in cases of PRAs that use only methods in bin 1. There also needs to be a process for assuring the necessary expertise if methods in bins 2 through
ACRS Subcommittee Members Feedback
6 are used.
* The staff briefed the ACRS Subcommittee on Reliability and PRA on February 5, 2020
* Subcommittee members did not identify need for changes
9 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


Improve process for and documentation of closure of F&Os
Primary Regulatory Driver for RG 1.200,
Revision 3
* Evolution of the peer review process
- Gap in Rev. 2 of RG 1.200 with respect to peer review of NDMs
- Significance of closing this gap, specifically for (Risk-Informed Technical Specification (RITS)-4b)
- Strategy to close this gap using PWROG-19027- NP and NEI 17-07
10
RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final


The requirement to retain and report all past Peer Review F&Os until re-evaluated by another Peer Review is an administrative burden that does not provide a benefit to either the utility or the NRC. The current process results in an additional burden for both in the effort required for the preparation of the discussion of PRA technical adequacy section in the License Amendment Requests followed by the NRC
A Gap in RG 1.200 and the ASME/ANS
review of the F&O resolution. The NRC review frequently generates subsequent NRC requests for additional information (RAIs) and finally the effort of licensee in preparing RAI responses. The only currently accepted F&O closure path is the use of the Peer Review process, which is an additional cost and strain on limited PRA resources. In order to reduce this burden on both licensees and NRC to retain, report and review the F&Os that have been resolved, there is a need to provide an additional cost effective, robust process to allow licensee to close F&Os and eliminate further NRC reviews.
Level 1/LERF PRA Standard
* For each technical element, the ASME/ANS Level 1/LERF PRA
standard provides high-level requirements (HLRs) and supporting requirements (SRs).
* 2009 version of the ASME/ANS Level 1/LERF PRA standard endorsed via Revision 2 to RG 1.200 does not provide HLRs or SRs for NDMs; Furthermore, there is no definition of what constitutes an NDM.


This process needs to be developed to allow closure of peer review findings that address both the technical expertise required to close a finding as well as the documentation required to support peer review finding closure. In addition, once a finding has been considered appropriately closed, no further licensee or NRC review of the finding should be required to support a risk informed regulatory submittal.
* This gap resulted in inefficiencies in the staffs review of NFPA 805 applications and loss of confidence of the peer review method to adequately peer review NDMs.


An appropriate closure process should consider:
11 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
*
11/5/20
If/When NRC review of the closure is required
Draft Final
*
The type of finding (e.g., finding related to methodology issue should be treated differently from findings related to errors or documentation)
*
Whether the finding resulted in a Supporting Requirement being considered Not Met
*
Findings related to Un-reviewed Analysis Methods.


Evaluate any additional gaps in current peer review process
Importance of Closing the Gap; Base PRA
Acceptability for an Application
12 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Risk-Informed Inservice Inspection
50.69 SSC Categorization TSTF-425, Surveillance Frequency Control Prgm.


To ensure that all open issues are addressed, the working group will conduct a thorough evaluation of all difficulties the NRC and industry have encountered with the peer review process. This will involve a benchmark of current practices against documented, NRC-endorsed NEI peer review guidance.
NFPA-805, Risk-Informed Fire Protection RITS-4b, Risk-Informed Completion Times Required scope, level of detail, technical robustness, and plant representation
* Greater reliance on PRA
* More flexibility for licensee
* More complex staff review Draft Final


Work Product/Goal
Current Solution to the Gap
* For RITS-4b applications, staff has imposed the following Administrative Technical Specification (TS)/License Condition:
...and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.


Following development of solutions to the major issues identified above, the working group will develop draft supporting guidance for RG 1.200. It is envisioned that this draft guidance may propose changes to NEI peer review guidance, and may also call for issuance of interim staff guidance on the topic.}}
13 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final
 
Leveraging the Commission Endorsed  Peer Review Process to Close Gap
*
SECY-99-256: Rulemaking Plan for Risk-Informing Special Treatment Requirements,  October 29, 1999
*
COMNJD-03-0002, Stabilizing the PRA Quality Expectations and Requirements, September 8, 2003
*
SECY-04-0118, Plan for the Implementation of the Commissions Phased Approach to Probabilistic Risk Assessment Quality, July 13,
2004
*
SRM-SRM-SECY-04-0118, Plan for the Implementation of the Commissions Phased Approach to Probabilistic Risk Assessment Quality, October 6, 2004.
 
*
Establishment of the peer review process using RG 1.200 and consensus standards
*
Peer review process acknowledged in regulations (10 CFR 50.69, November 2004)
14 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final
 
Approach to Close the Gap in RG 1.200,
Revision 3
* PWROG-19027-NP, Revision 2:
- Provides definitions related to NDMs, PRA maintenance, and PRA upgrade.
 
- Provides 6 HLRs and 21 SRs for peer review of NDMs (Are being considered for inclusion in the next edition of the ASME/ANS
Level 1/LERF PRA Standard)
* NEI 17-07, Revision 2:
- Delineates the process that peer reviewers must use to peer review NDMs in addition to other technical elements of the PRA.
 
* Emphasis has been added to close as opposed to disposition peer review finding relating to NDMs prior to using them in PRA models.
 
15 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final
 
Public Comments on DG-1362: Summary
* DG-1362 issued for public comment on 07/01/2020
- 30-day comment period ending 07/31/2020
* Received 19 public comments
- Nuclear Energy Institute (NEI; 15 comments including text in transmittal letter)
- Pressurized Water Reactor Owners Group (PWROG; 3 comments)
- Individual (1 comment)
* Public comments included responses to two questions in Federal Register notice (FRN) on the closure of peer review findings using an NRC-endorsed approach
* PWROG submitted updated report PWROG-19027-NP,
Revision 2, with its public comments
16 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final
 
Changes to DG-1362 Based on Public Comments
17 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Peer review of PRAs that credit planned modifications Clarified expectations for PRAs of operating plants that credit planned modifications
- Considered as a special circumstance
- Staff will address on case-by-case basis
- Peer review and submittal documentation should clearly identify and describe such modifications and design changes Draft Final
 
Changes to DG-1362 Based on Public Comments
18 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Correcting the definition of PRA
acceptability Added context to the definition of PRA
acceptability
- Determined for each risk-informed application
- Considers staff positions in RG 1.200, in application-specific regulatory guidance, and any related requirements Draft Final
 
Changes to DG-1362 Based on Public Comments
19 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Clarification of peer review of PRA
upgrade(s)
Clarified expectations for peer review of PRA upgrade(s)
- Performed prior to using the upgraded PRA model in support of a PRA application
- Either for an approved risk-informed program or in the submittal of a risk-informed PRA
application for NRC review
- Use of a newly developed method (NDM) in a PRA
is considered a PRA upgrade Draft Final
 
Changes to DG-1362 Based on Public Comments
20
RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Clarifying when differences between the 2005 and 2009 version of the Level 1/LERF PRA
standard should be identified in support of a license amendment request Clarified that differences between the 2005 and
2009 version of the Level 1/LERF PRA Standard need to be addressed only if 2005 version used to demonstrate base PRA acceptability Draft Final
 
Changes to DG-1362 Based on Public Comments
21 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Ensuring consistency of Appendix D to RG
1.200, Revision 3, Other Hazards, with Part 6 of the 2009 version of Level
1/LERF PRA Standard (ASME/ANS RA-Sa-
2009)
Revised Appendix D, Other Hazards to be consistent with Part 6 of the 2009 version of Level 1/LERF PRA Standard (ASME/ANS RA-Sa-
2009)
Draft Final
 
Changes to DG-1362 Based on Public Comments
22 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Removal of an clarification to NEI 17-07, Revision 2, on the documentation of the resolution of peer review findings Public comment identified guidance in NEI 17-07, Revision 2, that addressed a clarification in the public release version of DG-1362 Removal of an clarification to PWROG-
19027-NP, Revision 2, regarding PRA upgrade determination process PWROG-19027-NP, Revision 2, addressed a clarification in public release version of DG-1362 Draft Final
 
Changes to DG-1362 Based on Public Comments
23 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Closure of peer review findings (answers to FRN
questions)
Added expectations for disposition of peer review findings from any peer reviews
- Findings should be evaluated for their impact on risk-informed application
- Addressed with documented justification and necessary changes to the PRA
- Prior to use of PRA in risk-informed application Draft Final
 
Public Comments Resulting in No Changes to DG-1362
24 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Availability of RG 1.200,
Revision 2 for use after issuance of Revision 3
- Comment was addressed via publicly available NRC
staff response; It explicitly states that Revision 2 is not being withdrawn and, therefore, there is no need to modify DG.
 
- This practice is consistent with other RG revisions
- Staff, however, anticipates one revision of RG 1.200 to be followed for a given PRA application
- Deviations from the referenced revision of RG 1.200
used in an application submitted to the NRC, including alternatives from other revisions of RG 1.200, need to be identified and justified Draft Final
 
Public Comments Resulting in No Changes to DG-1362
25 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Synopsis of Comment Synopsis of Change to DG-1362 Change use of the term application to narrower term "licensing application" throughout DG-1362
-
The term application is used in RG 1.200
consistent with the definition of the term PRA
application from ASME/ANS RA-Sa-2009, as endorsed by the NRC
-
Application-specific staff positions on PRA
acceptability exists in corresponding guidance (e.g.,
Maintenance Rule, Integrated Leak Rate Test)
-
Change could challenge NRC staffs confidence in initiatives that rely heavily on PRA results (e.g.,
risk-informed Technical Specification completion time changes), especially post-NRC approval of a license amendment request Draft Final
 
Path Forward
26
* Staff considers ACRS Full Committee feedback
* Final reviews and concurrence
* Final publication late-2020/early-2021 RG 1.200, Revision 3 Briefing for the ACRS Full Committee
11/5/20
Draft Final}}


{{RG-Nav}}
{{RG-Nav}}

Latest revision as of 07:12, 16 March 2025

Rev 3 - ACRS Fc Briefing-draft-final-no-notes
ML20293A488
Person / Time
Issue date: 11/05/2020
From: Anders Gilbertson, Shilp Vasavada, Sunil Weerakkody
NRC/NRR/DRA, NRC/RES/DRA/PRB
To:
Weerakkody S
References
Download: ML20293A488 (26)
v • d • e


Regulatory Guide 1.200, Revision 3 Briefing for the Advisory Committee on Reactor Safeguards Full Committee Anders Gilbertson Technical Lead / Reliability and Risk Analyst RES/DRA/PRB

Anders.Gilbertson@nrc.gov November 5, 2020

Shilp Vasavada Senior Reliability and Risk Analyst NRR/DRA/APLC

Shilp.Vasavada@nrc.gov Sunil Weerakkody Senior Level Advisor NRR/DRA

Sunil.Weerakkody@nrc.gov

Overview

  • Purpose
  • Background
  • Changes incorporated into Revision 3
  • ACRS Subcommittee members feedback
  • Primary regulatory driver for Revision 3
  • Resolution of public comments on DG-1362
  • Path forward

2 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Purpose To brief the ACRS Full Committee and solicit feedback on the staffs resolution of public comments on the staffs proposed revision 3 to Regulatory Guide (RG) 1.200 (i.e., DG-1362*)

  • Available in the Agencywide Document Access and Management System (ADAMS) under accession No. ML19308B636

3 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Background

  • PRA acceptability is determined with respect to the following aspects of the base PRA:

- Scope

- Level of detail

- Conformance to consensus PRA standard technical elements (i.e., technical robustness)

- Plant representation

4 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Background - PRA Acceptability

5 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Each element depends on the other in order to demonstrate PRA acceptability This paradigm obviates the need for an in- depth staff review of the base PRA model Draft Final

Background - PRA Acceptability (cont)

6 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Risk-Informed Inservice Inspection

50.69 SSC Categorization TSTF-425, Surveillance Frequency Control Prgm.

NFPA-805, Risk-Informed Fire Protection RITS-4b, Risk-Informed Completion Times Required scope, level of detail, technical robustness, and plant representation

  • Greater reliance on PRA
  • More flexibility for licensee
  • More complex staff review Draft Final

Changes incorporated into RG 1.200,

Revision 3

  • Endorses new industry documents:

- NEI 17-07, Revision 2 (ML19241A615)

  • Consolidates predecessor industry PRA peer review guidance for different hazard groups

- PWROG-19027-NP, Revision 2 (ML20213C660)

  • Includes requirements for determining acceptability of newly developed methods (NDMs) and necessary submittal documentation
  • Includes process for differentiating between PRA

maintenance and a PRA upgrade

- ASME/ANS RA-S Case 1 (i.e., the seismic code case)

7 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Changes incorporated into RG 1.200,

Revision 3 (cont)

  • Provides a new glossary of terms

- Some terms adopted directly from PWROG-

19027-NP

  • Provides descriptions of hazards to be considered in the development of a PRA

RG 1.200, Revision 3, retains the staff endorsement of ASME/ANS RA-Sa-2009

8 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

ACRS Subcommittee Members Feedback

  • The staff briefed the ACRS Subcommittee on Reliability and PRA on February 5, 2020
  • Subcommittee members did not identify need for changes

9 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Primary Regulatory Driver for RG 1.200,

Revision 3

  • Evolution of the peer review process

- Gap in Rev. 2 of RG 1.200 with respect to peer review of NDMs

- Significance of closing this gap, specifically for (Risk-Informed Technical Specification (RITS)-4b)

- Strategy to close this gap using PWROG-19027- NP and NEI 17-07

10

RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

A Gap in RG 1.200 and the ASME/ANS

Level 1/LERF PRA Standard

  • For each technical element, the ASME/ANS Level 1/LERF PRA

standard provides high-level requirements (HLRs) and supporting requirements (SRs).

  • 2009 version of the ASME/ANS Level 1/LERF PRA standard endorsed via Revision 2 to RG 1.200 does not provide HLRs or SRs for NDMs; Furthermore, there is no definition of what constitutes an NDM.
  • This gap resulted in inefficiencies in the staffs review of NFPA 805 applications and loss of confidence of the peer review method to adequately peer review NDMs.

11 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Importance of Closing the Gap; Base PRA

Acceptability for an Application

12 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Risk-Informed Inservice Inspection

50.69 SSC Categorization TSTF-425, Surveillance Frequency Control Prgm.

NFPA-805, Risk-Informed Fire Protection RITS-4b, Risk-Informed Completion Times Required scope, level of detail, technical robustness, and plant representation

  • Greater reliance on PRA
  • More flexibility for licensee
  • More complex staff review Draft Final

Current Solution to the Gap

  • For RITS-4b applications, staff has imposed the following Administrative Technical Specification (TS)/License Condition:

...and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

13 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Leveraging the Commission Endorsed Peer Review Process to Close Gap

SECY-99-256: Rulemaking Plan for Risk-Informing Special Treatment Requirements, October 29, 1999

COMNJD-03-0002, Stabilizing the PRA Quality Expectations and Requirements, September 8, 2003

SECY-04-0118, Plan for the Implementation of the Commissions Phased Approach to Probabilistic Risk Assessment Quality, July 13,

2004

SRM-SRM-SECY-04-0118, Plan for the Implementation of the Commissions Phased Approach to Probabilistic Risk Assessment Quality, October 6, 2004.

Establishment of the peer review process using RG 1.200 and consensus standards

Peer review process acknowledged in regulations (10 CFR 50.69, November 2004)

14 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Approach to Close the Gap in RG 1.200,

Revision 3

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

- Provides 6 HLRs and 21 SRs for peer review of NDMs (Are being considered for inclusion in the next edition of the ASME/ANS

Level 1/LERF PRA Standard)

- Delineates the process that peer reviewers must use to peer review NDMs in addition to other technical elements of the PRA.

  • Emphasis has been added to close as opposed to disposition peer review finding relating to NDMs prior to using them in PRA models.

15 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Public Comments on DG-1362: Summary

  • DG-1362 issued for public comment on 07/01/2020

- 30-day comment period ending 07/31/2020

  • Received 19 public comments

- Nuclear Energy Institute (NEI; 15 comments including text in transmittal letter)

- Pressurized Water Reactor Owners Group (PWROG; 3 comments)

- Individual (1 comment)

  • Public comments included responses to two questions in Federal Register notice (FRN) on the closure of peer review findings using an NRC-endorsed approach

Revision 2, with its public comments

16 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final

Changes to DG-1362 Based on Public Comments

17 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Peer review of PRAs that credit planned modifications Clarified expectations for PRAs of operating plants that credit planned modifications

- Considered as a special circumstance

- Staff will address on case-by-case basis

- Peer review and submittal documentation should clearly identify and describe such modifications and design changes Draft Final

Changes to DG-1362 Based on Public Comments

18 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Correcting the definition of PRA

acceptability Added context to the definition of PRA

acceptability

- Determined for each risk-informed application

- Considers staff positions in RG 1.200, in application-specific regulatory guidance, and any related requirements Draft Final

Changes to DG-1362 Based on Public Comments

19 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Clarification of peer review of PRA

upgrade(s)

Clarified expectations for peer review of PRA upgrade(s)

- Performed prior to using the upgraded PRA model in support of a PRA application

- Either for an approved risk-informed program or in the submittal of a risk-informed PRA

application for NRC review

- Use of a newly developed method (NDM) in a PRA

is considered a PRA upgrade Draft Final

Changes to DG-1362 Based on Public Comments

20

RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Clarifying when differences between the 2005 and 2009 version of the Level 1/LERF PRA

standard should be identified in support of a license amendment request Clarified that differences between the 2005 and

2009 version of the Level 1/LERF PRA Standard need to be addressed only if 2005 version used to demonstrate base PRA acceptability Draft Final

Changes to DG-1362 Based on Public Comments

21 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Ensuring consistency of Appendix D to RG

1.200, Revision 3, Other Hazards, with Part 6 of the 2009 version of Level

1/LERF PRA Standard (ASME/ANS RA-Sa-

2009)

Revised Appendix D, Other Hazards to be consistent with Part 6 of the 2009 version of Level 1/LERF PRA Standard (ASME/ANS RA-Sa-

2009)

Draft Final

Changes to DG-1362 Based on Public Comments

22 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Removal of an clarification to NEI 17-07, Revision 2, on the documentation of the resolution of peer review findings Public comment identified guidance in NEI 17-07, Revision 2, that addressed a clarification in the public release version of DG-1362 Removal of an clarification to PWROG-

19027-NP, Revision 2, regarding PRA upgrade determination process PWROG-19027-NP, Revision 2, addressed a clarification in public release version of DG-1362 Draft Final

Changes to DG-1362 Based on Public Comments

23 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Closure of peer review findings (answers to FRN

questions)

Added expectations for disposition of peer review findings from any peer reviews

- Findings should be evaluated for their impact on risk-informed application

- Addressed with documented justification and necessary changes to the PRA

- Prior to use of PRA in risk-informed application Draft Final

Public Comments Resulting in No Changes to DG-1362

24 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Availability of RG 1.200,

Revision 2 for use after issuance of Revision 3

- Comment was addressed via publicly available NRC

staff response; It explicitly states that Revision 2 is not being withdrawn and, therefore, there is no need to modify DG.

- This practice is consistent with other RG revisions

- Staff, however, anticipates one revision of RG 1.200 to be followed for a given PRA application

- Deviations from the referenced revision of RG 1.200

used in an application submitted to the NRC, including alternatives from other revisions of RG 1.200, need to be identified and justified Draft Final

Public Comments Resulting in No Changes to DG-1362

25 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Synopsis of Comment Synopsis of Change to DG-1362 Change use of the term application to narrower term "licensing application" throughout DG-1362

-

The term application is used in RG 1.200

consistent with the definition of the term PRA

application from ASME/ANS RA-Sa-2009, as endorsed by the NRC

-

Application-specific staff positions on PRA

acceptability exists in corresponding guidance (e.g.,

Maintenance Rule, Integrated Leak Rate Test)

-

Change could challenge NRC staffs confidence in initiatives that rely heavily on PRA results (e.g.,

risk-informed Technical Specification completion time changes), especially post-NRC approval of a license amendment request Draft Final

Path Forward

26

  • Staff considers ACRS Full Committee feedback
  • Final reviews and concurrence
  • Final publication late-2020/early-2021 RG 1.200, Revision 3 Briefing for the ACRS Full Committee

11/5/20

Draft Final


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