ML18024A025

Approval for Credit for the Sequoyah Operational Safety Review Team to the Baseline Inspection Samples/Hours

ML18024A025
Person / Time
Site:	Sequoyah
Issue date:	01/24/2018
From:	Alan Blamey Division Reactor Projects II
To:	Shaun Anderson Office of Nuclear Reactor Regulation
References
Download: ML18024A025 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 24, 2018 MEMORANDUM TO: Shaun Anderson, Chief Reactor Inspection Branch Office of Nuclear Reactor Regulation FROM: Alan Blarney, Chief IRA!

Reactor Projects Branch 2 Division of Reactor Projects

SUBJECT:

APPROVAL FOR CREDIT FOR THE SEQUOYAH OPERATIONAL SAFETY REVIEW TEAM TO THE BASELINE INSPECTION SAMPLES/HOURS The purpose of this Memorandum is to request approval for the one-time credit, for the Seq uoyah Operational Safety Review Team (OSART), to the baseline inspection of the Reactor Oversight Program in accordance with MC 2515, Light-Water Reactor Inspection Program Operations Phase, Section 2515-08.05, Baseline Inspection Credit for Operational Safety Review Team Effort.

As an incentive to encourage licensee participation in the OSART mission, the NRC will grant a one-time regulatory credit (reduction in baseline inspection program) for those NRC baseline inspections, listed in Section 08.05, that overlap, either in part or fully, with the OSART review.

Specifically, MC 2515, Section 08.05 notes that:

In order for the region to take one-time credit for reducing baseline inspections, the areas for which the credit is to be given must have been documented in the OSART report. In addition, an NRC staff person should closely monitor the OSART activities, such as attending the teams briefings to the licensee. The staff person should assess whether the regulatory credit assumptions were appropriate. This person also needs a good understanding of the issues and recommendations made by the OSART. For NRC planning purposes, this effort is estimated to take approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. Also, the region should assure that the OSART inspection report is made publicly available.

During the Sequoyah OSART Mission the IAEA Team, by IAEA policy, would not allow the resident inspectors to observe the daily OSART meeting nor attend the daily team meetings with the licensee. Therefore, the resident inspectors were not able to fully observe specific OSART mission inspection discussions. Instead, the resident inspectors reviewed Sequoyahs CONTACT: Alan Blamey, Rll/DRP 404-997-4415

S. Anderson 2 Condition Reports (CRs), and they discussed the OSART mission with the Sequoyah licensing staff and operations staff during plant tours to gain insights into the issues identified by the OSART mission. In addition, the draft OSART report was reviewed by the resident inspectors, DRS Health Physics inspectors and Emergency Planning inspectors.

Based on MC 2515 and the average hours provided in each inspection procedure resource estimate, listed in MC 2515, Section 08.05, the maximum one-time OSART inspection credit is 231 hours0.00267 days <br />0.0642 hours <br />3.819444e-4 weeks <br />8.78955e-5 months <br />. For this OSART activity Region II recommends a one-time credit of 156 hours0.00181 days <br />0.0433 hours <br />2.579365e-4 weeks <br />5.9358e-5 months <br />. The following summarizes the basis for this recommendation. A more detailed inspection procedure (IP) review can be found in Attachment 1.

Radiation Safety inspections should be credited 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> out of a maximum possible 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br />.

The credit is based on a review of the radiation safety related inspection activities documented in the OSART draft report, final report and Radiation Protection activities observed during the OSART inspection. Because all of the inspection areas contained within the NRC inspection procedures (IP 71124.01 thru IP 71124.08) were not observed during the inspection nor documented in the report, the recommended hours credited to NRC Region II radiation safety inspection activities were reduced.

Emergency Planning (EP) inspections should be credited 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> out of a maximum possible 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The biennial EP IPs 71114.03, Emergency Response Organization Staffing and Augmentation System and 71114.05, Maintenance of Emergency Preparedness, were completed on September 22, 2017 (after completion of the OSART inspection and prior to issuance of the OSART inspection report). Providing credit for inspections that will not be performed until September 2019, did not meet the intent of the credit guidelines established in IMC 2515 sections 08.04, Completion of Inspection Procedures, and 08.05.

Surveillance Testing and Fire Protection (IP 71111.22 and IP 71111 .O5AQ) should be credited 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> out of maximum possible 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />. The credit is based on the summary of surveillance and fire protection inspection activities documented in the OSART draft report, final report and activities observed during the OSART inspection. Because the inspection areas contained within the NRC inspection procedures (IP 71111.22 thru IP 71111 .O5AQ) were not observed during the inspection nor documented in the report, no credit is warranted for these areas.

Problem Identification and Resolution (IP 71152B), should be given full credit of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />. The credit is based on the inspection activities documented in the OSART draft report, final report and activities observed during the OSART inspection.

Region II also reviewed the past inspection credit that was provided for OSART inspections.

Specifically, at Seabrook in June 2011, the NRC credited 169 hours0.00196 days <br />0.0469 hours <br />2.794312e-4 weeks <br />6.43045e-5 months <br />, providing full regulatory inspection credit for all areas with the exception of Emergency Preparedness which was zero and Pl&R which was 25% vice 50%. As noted previously Region II is recommending 156 hours0.00181 days <br />0.0433 hours <br />2.579365e-4 weeks <br />5.9358e-5 months <br /> of credit be given.

In addition, MC 2515 notes that the region should ensure that the OSART report will be made publically available. Since this is an IAEA report, not an NRC report, Region II will work with the Office of International Programs to determine if the Sequoyah OSART report will be publically available.

S. Anderson 3 If you need more information about the content of this memorandum, please contact me at 404-997-4415.

Enclosures:

1. MC 2515-08.05

2. Attachment 1, Sequoyah OSART Crediting Recommendation

ML18024A025 OFFICE RII/DRP RII/DRP NAME ABlamey JMunday DATE 1/23/2018 1/23/2018 08.05 Baseline Inspection Credit for Operational Safety Review Team Effort. The Operational Safety Review Team (OSART) review is performed by senior staff members from International Atomic Energy Agency member states. The OSART missions offer a means of assessing licensee performance and reinforcing plant self-assessments through an independent assessment process. OSARTs focus is on the safety and reliability of plant operation. They review the operation of the plant and the performance of the plants management and staff rather than the adequacy of the plants design and compliance with its licensing basis. Based on a review of sample OSART reports and the OSART guidelines, the staff determined that although the OSART review is not risk-informed, some areas of the review overlap with the ROP baseline inspection program. The NRC believes that it would be beneficial for the U.S.

nuclear power industry to continue its participation in the OSART missions.

As an incentive to encourage licensee participation in the OSART mission, the NRC grants a one-time regulatory credit (reduction in baseline inspection program) for those NRC baseline inspections that overlap, either in part or fully, with the OSART review. Accordingly, a 25 percent ROP baseline inspection credit shall be given for the following baseline inspection procedures:

• IP 711 1 1.22, Surveillance Testing

• lP 71111 .O5AQ, Fire Protection

• 1P71124.01, Radiologica l Hazard Assessment and Exposure Controls

• 1P71124.02, Occupational ALARA Planning and Controls

• lP71124.03, In-Plant Airborne Radioactivity Control and Mitigation

• IP71124.04, Occupational Dose Assessment

• 1P71124.05, Radiation Monitoring Instrumentation

• 1P71124.06, Radioactive Gaseous and Liquid Effluent Treatment

• IP71124.07, Radiological Environmental Monitoring Program

• lP71124.08, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation In addition, a 50 percent ROP baseline inspection credit shall be given for the following inspection procedures:

• IP 71114.03, Emergency Response Organization Staffing and Augmentation System

• IP 71114.05, Maintenance of Emergency Preparedness

• IP 71152B, Problem Identification and Resolution In order for the region to take one-time credit for reducing baseline inspections, the areas for which the credit is to be given must have been documented in the OSART report. In addition, an NRC staff person should closely monitor the OSART activities, such as attending the teams briefings to the licensee. The staff person should assess whether the regulatory credit assumptions were appropriate. This person also needs a good understanding of the issues and recommendations made by the OSART. For NRC planning purposes, this effort is estimated to take approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. Also, the region should assure that the OSART inspection report is made publicly available. Specific OSART findings should not normally be referenced or followed-up by the NRC, however, where a significant safety issue (potentially greater than Green) or a potential violation of an NRC requirement is identified, the NRC will independently conduct an appropriate baseline inspection to disposition potential violations and assess the significance of the finding in accordance with the ROP. These findings will be documented in Enclosure 1

accordance with NRC Inspection Manual Chapter fIMC) 0612, Power Reactor Inspection Reports, and will also be processed as performance assessment inputs equivalent to NRC identified findings in accordance with IMC 0305, Operating Reactor Assessment Program.

The staff will perform any additional inspections for those findings that have a significance greater than Green in accordance with NRCs Action Matrix. The baseline inspection credit and NRC staff position described above are communicated to the Commission via a memorandum dated July 16, 2003 (ADAMS Accession Numbers: ML031620369, ML030930251, MLO31 6020346).

Enclosure I

Sequoyah OSART Creditinq Recommendation Sequoyah OSART RP Crediting Recommendation 1 2018 2019 Inspection One-Time OSART Cred t Frequency IP Requirements One-Time OSART Credit

% IP Sample  % IP Hours  % IP RP Program Inspections Sample Inspection Sample Hours /o IP Hours Samp Reduction Samples Reduction 25% Reduction size Hours Reduction Reduction Hours les IP 71124.01, Radiological Hazard Assessment and Annual 7 32 2 29% 9 29% N/A N/A N/A N/A Exposure Controls IP 71124.02, Occupational ALARA Planning and Biennial 5 54 2 40% 22 40% N/A N/A N/A N/A Controls IP 71124.03, In-Plant N/A N/A Biennial 4 16 0 0% 0 0% N/A N/A Airborne Radioactivity Control and Mitigation 1P71124.04, Occupational Biennial 5 20 0 0% 0 0% N/A N/A N/A N/A Dose Assessment IP 71124.05, Radiation Biennial 3 32 0 0% 0 0%

Monitoring Instrumentation N/A N/A N/A N/A lP 71124.06, Radioactive 0 0% 0 0%

Gaseous and Liquid Effluent Biennial 6 35 N/A N/A N/A N/A Treatment IP 71124.07, Radiological Environmental Monitoring Biennial 3 29 N/A N/A N/A N/A 0 0% 0 0%

Program IP 71124.08, Radioactive Solid Waste Processing and 0 0% 0 0%

Radioactive Material Biennial 6 34 N/A N/A N/A N/A Handling, Storage, and Transportation MC 2515 Maximum Hours 63 Credit (25%

Total RP Inspection Hours 252 Scheduled, 2018-2019 Total RP Hours Credited for OSART, 2018-2019 Total RP % Credit for 12°0 OSART, 2018-2019 Note: Inspection hours are based on the average hours provided by the inspection procedure. N/A is for the second performance of an annual (one-time credit) and for the year that the biennial not performed.

Page 1 Attachment; Enclosure 2

Sequoyah OSART Crediting Recommendation Sequoyah OSART EP Crediting Recommendation 201$ 2019 I I Inspection One-Time OSART Credit Frequency IP Requirements One-Time OSART Credit EP Program Inspections Sample Inspection Sample  % IP Hours  % i Sample  % IP Hours  % P Samples Reduction Hours Reduction Samples Reduction Hours 50% Reduction size Hours Reduction P 71114.03, Emergency Response Organization N/A N/A 0 0% 0 0%

Biennial 1 8 N/A N/A Staffing and Augmentation System IP 71114.05, Maintenance 0% 0 0%

N/A N/A 0 of Emergency Biennial 1 12 N/A N/A Preparedness MC 2515 Maximum Hours 10 Credit (50%

Total EP Inspection Hours 20 Scheduled, 2018-2019 Total EP Hours Credited for 0

OSART, 2018-2019 Total EP % Credit for OSART, 2018-2019 Note: Inspection hours are based on the average hours provided by the inspection procedure. N/A is for the second performance of an annual (one-time credit) and for the year that the biennial not performed.

Page 2 Attachment 1

Seq uoyah OSART Crediting Recommendation Sequoyah OSART Resident Crediting Recommendation 2018 2019 Inspection One-Ti me OSART Cred it Frequency IP Requirements One-Time OSART Credit Resident Program Sample  % IP Hours  % IP Sample Inspection Sample  % IP Hours ° 1 Reduction Samples Reduction Hours Inspections size Hours Reduction Samples Reduction Hours 25% and 50% Reduction IP 71111.22, Surveillance Testing (22 samples to 16 Annual 18 100 0 0% 0 0% N/A N/A N/A N/A samples)

IP 71111.O5AQ, Fire Protection (24 samples to Annual 16 35 0 0% 0 0% N/A N/A N/A N/A 18 samples)

CAP 50% Reduction P 71152B, Problem Biennial 1 250 N/A N/A N/A N/A 0 0% 125 50%

Identification and Resolution 33.75/125 MC 2515 Maximum Hours Total Credit (25%/50%)

158.75 Total Resident Inspection Hours Scheduled, 2018- 385 2019 Total Resident Hours 0/125 Credited for OSART, 2018- Total 125 2019 Total Resident % Credit for o°/0 /500/0 OSART, 2018-2019 Note: Inspection hours are based on the average hours provided by the inspection procedure. N/A is for the second performance of an annual (one-time credit) and for the year that the biennial not performed.

Page 3 Attachment 1