ML23010A231

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EPRI - Crmf Meeting January 2023_Clean
ML23010A231
Person / Time
Issue date: 01/09/2023
From: John Hanna
NRC/NRR/DRA/APOB
To:
References
Download: ML23010A231 (18)


Text

Perspectives on FLEX, PRA Configuration Control & the NRCs SPAR models EPRI Risk Technology Meeting: January 9, 2023 John David Hanna, Senior Reactor Analyst Division of Risk Assessment Office of Nuclear Reactor Regulation 1

AGENDA PRA Configuration Control Tabletops:

Perspectives Thus Far - The Good & The Opportunities & The Inspection Ideas 2

FLEX/Mitigating Strategies Observations and PRA Aspects SPAR: KM/KT

3 FLEX and the Mitigating Strategies:

  • Staff perspectives on PWROG reliability data
  • Substantial progress has been made by industry in developing best practices and preventive maintenance strategies
  • Equipment Failures in 2021 & 2022
  • Continued battery failures (Callaway, Comanche Peak, STP &

LaSalle)

  • FLEX EDG or Marine Turbine Generator failures (Susquehanna, ANO, Perry)
  • Design issue with pumps/generators being wired incorrectly (Waterford).
  • Output breaker issues (Clinton, Riverbend)
  • Status of FLEX/Mitigating Strategies incorporation in PRA models FLEX PRA Modeling

4 PRA Configuration Control Table-Top:

Perspectives Thus Far - The Good, The Opportunities, and The Inspection Ideas

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 (Contd)

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.

All eight tabletops have been completed:

- Based on the reviews conducted to date, NRC staff have confirmed licensees are meeting the consensus standard but identified several observations 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 High-Level Plan ROP Change Control Process Conduct Tabletops Finalize Information Gathering Needs Refine guidance and share PRA Configuration Control Framework recommendations for feedback

8 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 draft proposal at ROP monthly public meeting May 2023 Discuss any feedback at ROP Monthly public meeting June 2023 Revise Tier 2 inspection guidance December 2023 Overall Plan Enter ROP change control process July 2023

9 Observations from Tabletops: The Good

  • Understanding of Licensees PRA Configuration Control Programs

- Monitoring of Engineering Changes

  • Exercise potential inspection guidance with licensees PRA staff
  • Representative picture of PRA Configuration Control program implementation
  • Licensees support, responsiveness, and feedback

10 Observations from Tabletops:

The Opportunities

  • PRA Configuration Control (PCC) vs. Peer Review Process:

- PCC inspection will have an element of technical adequacy as part of effort per ASME standard

- Through the course of a change review of PCC implementation, plant representation will remain a priority

- PCC Upgrades, if selected, will be based on F&O reviews

11 The Opportunities, Contd Implementation of PCC Under Existing Regulatory Framework (Not Appendix B)

Potential Program Vulnerabilities:

  • (One) Knowledge based program w/ inconsistent implementation
  • (General) Operations, Maintenance and Industry-Wide Operational History monitoring, less formal than Engineering Changes Observations:
  • (One) Generic data update not completed since 2010, last data update 2016. Approved: SFCP, RICT, 50.69
  • (Two) Industry Wide Operating Experience (i.e., OPC) impact on Initiating Events Technical Element not evaluated

12 Inspection Enhancement - Initial Thoughts Some possible ideas (So-Far):

- Comprehensive Engineering Team Inspection (CETI)

(Internal Events, Internal Flooding & Other Approved Hazards)

  • Focused Engineering Inspection (FEI) Internal Fire

- Resident Inspector Baseline Procedures. All hazards.

SPAR - KM/KT 13

14 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)

15 FY2021 St. Lucie Unit 1 is currently being benchmarked by NRC and is anticipated to be completed by end October, early November Calvert Cliffs Unit 1 is currently being benchmarked at INL and is anticipated to be complete by end of November St. Lucie Unit 2 and Calvert Cliffs Unit 2 will start Additional SPAR models will be identified for benchmark based on provided information and date of last benchmark FY2022 Model update completed for Diablo Canyon, Comanche Peak, South Texas Project, Harris, Monticello.

Added Internal Flooding Hazard: David-Besse Incorporated 2020 INL Industry Average Parameters Estimates into all SPAR Models SPAR Models Update FY 2023

16 Make risk information accessible to all NRC staff Gather key risk results in an easy-to-use interactive dashboard Remove barriers and support communication of risk insights Support Be RiskSMART and our path to becoming a modern, risk-informed regulator SPAR-DASH

17 Assess events &

hazards Plant-to-plant comparison Ranking risk importance Off-normal conditions Periodic update

18 Questions?