NEI 05-04/07-12/12-06 Appendix F, Fact & Observation (F&O) Close-Out with Independent Assessment

Most utilities have completed the peer reviews for both Full-Power Internal Events (FPIE) and Fire PRAs in support of Risk-Informed Applications (NFPA-805, etc.) Some have also completed the peer reviews for Seismic and High Winds PRAs.

Many of these peer reviews have been sponsored by Owners Groups following NEI peer review guidance documents (NEI 05-04). Depending on specific conditions and quality of PRAs, some peer reviews have resulted in large number of Facts and Observations (F&Os). Full and focused-scope follow-up peer reviews have been used to close-out these F&Os. These reviews can be labor intensive, expensive and could also generate new F&Os creating an on-going concerns for closing out F&Os. There have been some reported concerns with assessment consistency.

A consistent industry-wide F&O close-out process has been proposed and draft NEI guidance has been developed as Appendix X to NEI 05-04. The independent assessment process is recommended for its efficiency and also as a means to provide justification for adequate resolution of F&Os when applying for NRC risk informed applications.

EPM has extensive experience with providing focused F&O closeout assessments, as well as, experience with the recent F&O closeout process pilot projects. EPM can provide resources to fully meet the requirements for these reviews or provide specific support to teams providing these reviews. Whether you need a team lead or qualified and independent highly experienced and qualified team members, EPM can meet your needs. We can review your F&Os and then provide a number of cost effective options for meeting your specific needs and schedules. EPM has highly experienced former utility and NRC personnel that not only understand the needs for the independent F&O closeout process, but also bring with them the perspectives that provides additional added value.