ML18057B466
| ML18057B466 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/2017 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Widmayer D, ACRS | |
| References | |
| NRC-3416 | |
| Download: ML18057B466 (177) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
Rockville, Maryland Date:
Thursday, December 7, 2017 Work Order No.:
NRC-3416 Pages 1-101 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 649TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 OPEN SESSION 8
+ + + + +
9 THURSDAY 10 DECEMBER 7, 2017 11
+ + + + +
12 ROCKVILLE, MARYLAND 13
+ + + + +
14 The Advisory Committee met at the Nuclear 15 Regulatory Commission, Two White Flint North, Room 16 T2B1, 11545 Rockville Pike, at 8:30 a.m., Dennis Bley, 17 Chairman, presiding.
18 19 COMMITTEE MEMBERS:
20 DENNIS BLEY, Chairman 21 MICHAEL CORRADINI, Vice Chairman 22 PETER RICCARDELLA, Member-at-Large 23 RONALD G. BALLINGER, Member 24 CHARLES H. BROWN, JR., Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 MARGARET CHU, Member 1
VESNA B. DIMITRIJEVIC, Member 2
WALTER L. KIRCHNER, Member 3
JOSE MARCH-LEUBA, Member 4
DANA A. POWERS, Member 5
HAROLD B. RAY, Member 6
JOY REMPE, Member 7
PETER RICCARDELLA, Member 8
JOHN W. STETKAR, Member 9
MATTHEW W. SUNSERI, Member 10 11 DESIGNATED FEDERAL OFFICIAL:
12 DEREK WIDMAYER 13 14 ALSO PRESENT:
15 GREG BOWMAN, NRR 16 JIM ISOM, NRR 17 DAN MERZKE, NRR 18 ANDREA D. VEIL, Executive Director, ACRS 19 20
- Present via telephone 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 CONTENTS 1
Opening Remarks by the ACRS Chairman 4
2 Annual Reactor Operating Experience.......
7 3
Adjourn....................
101 4
5 6
7 8
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4 P R O C E E D I N G S 1
8:30 a.m.
2 CHAIRMAN BLEY: The meeting will now come 3
to order. It's my honor and privilege to welcome you 4
to the first day of the 649th meeting of the Advisory 5
Committee on Reactor Safeguards.
6 During today's meeting the committee will 7
consider the following. Our annual review of 8
operating experience. Our assessment of the quality 9
of selected NRC research projects. The future ACRS 10 activities and report on planning and procedures 11 subcommittee, and reconciliation of ACRS comments and 12 recommendations. And four, our biennial review of NRC 13 research projects.
14 The ACRS was established by statute and is 15 governed by the Federal Advisory Committee Act, FACA.
16 As such the meeting is being conducted in accordance 17 with the provisions of FACA.
18 That means that the committee can only 19 speak through our published letter reports. We hold 20 meetings to gather information to support our 21 deliberations.
22 Interested parties who wish to provide 23 comments can contact our offices requesting time after 24 the Federal Register notice describing the meeting is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 published.
1 That said, we also set aside 10 minutes 2
for spur of the moment comments from members of the 3
public.
4 Written comments are also welcome. Mr.
5 Derek Widmayer is the designated federal official for 6
the initial portion of this meeting.
7 The ACRS section of the U.S. NRC public 8
website provides our charter, our bylaws, letter 9
reports and full transcripts of all full and 10 subcommittee meetings including the slides presented 11 at these meetings.
12 We have received no written comments or 13 requests to make oral statements from members of the 14 public regarding today's sessions.
15 There is a telephone bridge line. To 16 preclude interruption of the meeting the phone will be 17 placed in a listen-in mode during presentations and 18 committee discussion.
19 To my surprise it appears we are also 20 being webcast again this morning. You can go to the 21 NRC website and follow the links to listen in. The 22 sound is usually better on that path than through the 23 bridge line although you can't talk to the committee 24 that way.
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6 A transcript of portions of the meeting is 1
being kept and it is requested that speakers use one 2
of the microphones, identify themselves and speak with 3
sufficient clarity and volume that they may be readily 4
heard.
5 As an item of current interest I would 6
like to welcome our new member to the committee, Dr.
7 Vesna Dimitrijevic. I can't even say it this morning.
8 MEMBER BALLINGER: Dimitrijevic.
9 CHAIRMAN BLEY: She was the technical lead 10 for AREVA's U.S. EPR design certification. As a 11 technical expert Dr. Dimitrijevic has participated in 12 the development of diverse PRA methods including risk-13 informed applications for Gen 3 plants, the EPRI risk-14 informed in-service inspection program, and internal 15 flooding for fire and PRA guidance.
16 And even more impressive to me I think 17 she's the only present or past member of this 18 committee to be a chess grand master. I saw you on 19 the website.
20 Vesna, welcome to the committee.
21 (Applause) 22 CHAIRMAN BLEY: At this time I'm going to 23 turn the meeting over to Dick Skillman for our first 24 session. Dick?
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7 MEMBER SKILLMAN: Mr. Chairman, sir, thank 1
you.
2 Colleagues, this is a meeting that we 3
rarely spend a lot of time on. Most of our time is 4
spent on looking at applications, at very high-tech 5
computer programs, things that are very, very 6
sophisticated.
7 For the next two hours, 120 minutes, we're 8
going to talk about the reactor oversight process.
9 And this is where our recon team, the 10 inspectors and the inspection agency within this 11 building confirm that the licensees are doing what 12 they are supposed to be doing.
13 This is just an extraordinary important 14 piece of our nuclear business.
15 What Derek and I have prepared is the data 16 for 2015 and 2016 of the plant data for the United 17 States for 101 nuclear power plants.
18 But as an introduction to that we've asked 19 Jim and Dan to talk about the changes to the reactor 20 oversight process.
21 Now we went through this if you will about 22 18 months ago. There were some changes on what causes 23 a plant to be in column 2 or column 3. What several 24 whites or a white plus a yellow mean in terms of risk.
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8 And those adjustments are now embedded 1
into the reactor oversight process. But those were 2
changes.
3 And so Dan and Jim are going to talk about 4
the changes to the reactor oversight process. And 5
when they're completed we'll proceed through the data.
6 And with that I'll turn it over to NRC 7
staff. Please proceed.
8 MR. MERZKE: Good morning. Thank you for 9
having us at your meeting today. We appreciate the 10 opportunity to come and talk to you about what the 11 folks at the Office of Nuclear Reactor Regulation have 12 been doing.
13 I'm Dan Merzke. I'm the assessment 14 program lead for the reactor oversight process in the 15 ROP assessment branch. With me today is Jim Isom 16 who's in the inspection programs branch.
17 I think between the two of us we've 18 implemented most of the recent changes that we're 19 going to talk about today, the reactor oversight 20 process.
21 And basically we're looking at the impact 22 of those changes up to date.
23 So as a little background in 2012 the 24 staff undertook an effort referred to as the ROP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 Enhancement Project which was to take a fresh look at 1
the ROP, determine if the ROP was helping us achieve 2
what we wanted to achieve as a regulator.
3 Is it appropriate for the current 4
environment. What's working, what's not working and 5
what we can improve.
6 The staff reviewed all the baseline 7
inspections, communications initiatives and the 8
assessment program as part of this project.
9 Concurrently, the Commission directed the 10 staff to undertake an independent review of the ROP's 11 objectives and implementation including the relative 12 roles of headquarters and regional staff, our 13 interactions with industry over performance indicator 14 assessments and the effectiveness of NRC's assessment 15 of substantive crosscutting issues.
16 That report that was issued documented 8 17 recommendations and 10 suggestions to improve the ROP.
18 Staff dispositioned each of these recommendations and 19 suggestions and some of those are the subject of our 20 discussion this morning.
21 The key message that I want to leave you 22 with is that the ROP is constantly evolving to 23 recommendations made from the ROP feedback program, 24 annual self-assessments, independent assessments of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 the program through entities such as the Office of 1
Inspector General and the Government Accountability 2
Office and feedback received from stakeholders during 3
our monthly ROP working group public meetings.
4 Today we'll be discussing several 5
noteworthy changes to the ROP as a result of those 6
efforts.
7 And in chronological order they are 8
changes to repetitive degraded cornerstone, 9
substantive crosscutting issue process, the action 10 matrix criteria, the inspection finding resolution 11 management project or process which has been recently 12 implemented, and the significance determination 13 process
- area, and changes to the engineering 14 inspections.
15 In 2015 the staff revised the definition 16 of the repetitive degraded cornerstone which was from 17 the beginning of the ROP in 2000 the definition of 18 degraded cornerstone was one yellow input in the 19 action matrix or two white inputs in the same 20 cornerstone.
21 An input is either an inspection finding 22 which is greater than green, i.e., white, yellow, or 23 red, or a performance indicator again that crosses a 24 threshold from green to white to yellow or red.
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11 I'll quickly -- I wasn't going to talk 1
about it, but there may be some folks here who are not 2
familiar with the cornerstones, the safety 3
cornerstones of the ROP which make up the framework of 4
the ROP.
5 There are seven cornerstones, initiating 6
events, mitigating systems and barrier integrity, and 7
emergency preparedness make up the reactor safety 8
strategic performance area.
9 And then we have occupational radiation 10 safety and public radiation safety cornerstones as 11 part of the radiation safety strategic performance 12 area.
13 And the final cornerstone is security. So 14 those are our seven cornerstones.
15 CHAIRMAN BLEY: Dan?
16 MR. MERZKE: Yes.
17 CHAIRMAN BLEY: There's another thing not 18 everyone may be familiar with. Maybe you could say a 19 few words about it. And that's the action matrix in 20 this column 3 stuff.
21 MR. MERZKE: Sure. The action matrix as 22 defined in inspection manual chapter 03-05.
23 What it is is a matrix which prescribes 24 five columns in which we place reactors as far as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 their performance.
1 The columns are numbered one through five.
2 Column one is the licensee response column. That 3
column is defined to be a licensee has all green 4
inputs in the action matrix, i.e., green inspection 5
findings and green performance indicators throughout 6
the assessment period. The assessment period is 7
basically a 12-month period, previous period.
8 To move to column two a licensee might 9
have one white input, i.e., either an inspection 10 finding or a performance indicator, or as many as two 11 whites now in the same cornerstone will put a licensee 12 into column two. Sure.
13 MEMBER SKILLMAN: Slide 43 on your package 14 is what Dan is going through now. This is good 15 information. Since you're presenting it we won't go 16 into detail later but for those colleagues who wish to 17 follow along what Dan is presenting is on slide 43.
18 MR. MERZKE: The action matrix actually 19 prescribes the regulatory actions that the NRC will 20 take in response to the licensee performance based on 21 the column they're in.
22 It prescribes the supplemental inspection 23 activities, communication activities, management 24 involvement based on again licensee performance.
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13 And as you'll see in the action matrix the 1
further you go right, the licensee moves right in the 2
action matrix, that indicates declining performance.
3 And also you'll see that there will be 4
increased regulatory actions and increased management 5
attention to that licensee. Yes, sir.
6 MEMBER BROWN: This may be a dumb question 7
but findings are white, yellow, red and green is zero 8
I take it.
9 My question really has nothing to do with 10 those, but are there any category of findings that are 11 of such a level that they don't really fall -- they 12 don't get a white reading but their observations or 13 findings --
14 MR. MERZKE: Yes, sir, there are. A 15 finding is defined to be a performance deficiency 16 which is a licensee's failure to meet a requirement or 17 a standard, a self-imposed standard.
18 Now what the staff does, inspectors do 19 once they determine there's a performance deficiency 20 when they're under inspection they'll start processing 21 that for significance.
22 The first question they ask is is it minor 23 or more than minor. And IMC inspection manual chapter 24 06-12 appendix B right now has several questions that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 the inspectors ask in order to determine if it's minor 1
or more than minor.
2 If it's minor it doesn't get documented in 3
an inspection report. If it's more than minor that 4
crosses the threshold and now it's defined to be an 5
inspection finding. And that will be documented in 6
the inspection report.
7 MEMBER BROWN: All right. So there's some 8
discretion allowed to the inspections to figure this 9
out based on the guidance in the inspection document.
10 MR. MERZKE: There's a major effort 11 ongoing right now to refine that criteria that 12 separates the minor from the more than minor criteria.
13 Because there is some subjectivity in 14 interpreting those questions and unfortunately that 15 results in some inconsistency in how the regions apply 16 that guidance.
17 MR. BOWMAN: This is Greg Bowman from DRS.
18 Maybe this goes without saying but even in cases where 19 we have a minor issue that doesn't get documented 20 licensees are required to correct the issue. It's not 21 documented but it still needs to be fixed.
22 MEMBER BROWN: Thank you very much.
23 MR. MERZKE: Does that answer your 24 question on the action matrix?
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15 MEMBER BROWN: Yes, thank you.
1 MR. MERZKE: Okay. So, the repetitive 2
degraded cornerstone was -- it was actually the change 3
which we made to the repetitive degraded cornerstone 4
which originally was a cornerstone that was degraded 5
and that put a licensee in column three for the action 6
matrix.
7 If they were in a degraded cornerstone for 8
more than four consecutive quarters they would 9
automatically be transitioned to column four which is 10 the repetitive degraded cornerstone or multiple 11 degraded cornerstone, one or the other.
12 But column four is a significant increase 13 in regulatory activity where the NRC goes from 14 supplemental inspection of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> to inspection of 15 3,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> or more. It's a very intrusive inspection 16 and licensees don't want to be in column four.
17 MEMBER POWERS: If a licensee had 18 identified or you had identified a
degraded 19 cornerstone and they set upon an activity to correct 20 same and it extended over -- per plan over four 21 quarters do you move him?
22 MR. MERZKE: The process would have had 23 them moving automatically. Unless the supplemental 24 inspection, in this case a 95002 supplemental 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 inspection was completed, the exit meeting was 1
completed by the end of the fourth quarter in which 2
they were in the degraded condition then they would 3
automatically be transitioned.
4 Unless the staff submitted a deviation 5
request.
6 MEMBER POWERS: I would think that you'd 7
want to --
8 MR. MERZKE: There's a deviation process 9
where if the staff feels that the licensee doesn't 10 deserve to be placed into that column for some reason 11 then we would follow that process and not move them.
12 But that would be an approval process at the EDO 13 level.
14 MEMBER POWERS: And that's fine as long as 15 you have -- I mean if per plan the guy says you're 16 right, we've got a degraded cornerstone. It takes me 17 a year and a half to fix it. And here's my plan for 18 fixing it. I mean you're just belaboring him to move 19 him.
20 MR. MERZKE: This initiative actually was 21 not an initiative requested by industry which is 22 unusual. We would expect that maybe.
23 But this was actually requested by the 24 regions because they're having a very difficult time 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 getting that supplemental inspection completed within 1
that four quarter period.
2 MEMBER POWERS: That's true.
3 MR. MERZKE: So we thought it would be 4
helpful for the regions if they had an extra quarter 5
in which to schedule and complete that inspection.
6 Because it is a very -- licensees in that 7
position put a lot of effort into preparing for those 8
inspections and getting those corrective actions in 9
place.
10 So it takes some time for them to get that 11 done not counting the time that it takes for us to 12 actually make that final determination that puts them 13 in column three or the degraded cornerstone.
14 So we did add that additional quarter. It 15 was not without controversy. We did have a different 16 professional opinion when we made that revision.
17 But the independent DPO panel that was 18 stood up to review that vindicated our efforts and the 19 change to the repetitive degraded cornerstone stood.
20 So basically the change added an 21 additional quarter to that degraded cornerstone 22 condition before moving to column four, the repetitive 23 degraded cornerstone. Basically we added a quarter.
24 And the impact basically has been there 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 has been no impact. No licensee has met the criteria 1
for a repetitive degraded cornerstone since Pilgrim 2
moved in 2014. And that includes the original 3
criteria as well as the revised criteria.
4 CHAIRMAN BLEY: There was some years ago, 5
maybe eight, a commissioner who expressed concern that 6
maybe there was a way licensees could game this 7
process and not really be taking care of safety but 8
just meeting the rules of the process.
9 Did you folks talk about that and do you 10 have any feelings about that?
11 MR. MERZKE: I am not familiar with that 12 concern.
13 (Simultaneous speaking) 14 MR. MERZKE: There's always a concern that 15 licensees are gaming the system quote unquote. We 16 have also concerns that the regions are gaming the 17 system in other areas.
18 We look at that very carefully. We try to 19 adjust the program guidance to make sure that gaming 20 isn't taking place.
21 I'll throw out one example, significance 22 determination process timeliness. That timeliness 23 requirement is 90 days from the time that we document 24 a greater than green inspection finding, a potentially 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 greater than green inspection finding and an official 1
correspondence is publicly available to the time we 2
make that final significance determination.
3 Sometimes that finding isn't officially 4
determined until the choice letter is issued which is 5
already well into the significance determination 6
process. That's an example of gaming the system.
7 Now we'll talk about changes that we're 8
making to the significance determination process to 9
eliminate that potential gaming by creating a metric 10 and ensuring that identification of that performance, 11 that inspection finding is done in a more timely 12 fashion.
13 So we do make program adjustments to watch 14 out for things like that.
15 CHAIRMAN BLEY: Thanks.
16 MR. MERZKE: Sure. That's probably more 17 than I wanted to tell you.
18 (Laughter) 19 CHAIRMAN BLEY: It kind of happens here.
20 MR. MERZKE: It happens. So let's just 21 acknowledge it.
22 The next area that we put some effort into 23 was the substantive crosscutting issue process. The 24 substantive crosscutting issue process was implemented 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 in the ERP in 2006 as part of the Davis-Besse lessons 1
learned effort.
2 Weak safety culture was identified as a 3
root cause of the reactor vessel head degradation, 4
Davis-Besse, and the task force report recommended the 5
staff review inspections and plant assessment 6
processes to determine whether sufficient processes 7
were in place to identify and appropriately 8
disposition the types of problems experienced in 9
Davis-Besse.
10 In an SRM SECY-04011 that the Commission 11 issued the Commission directed the staff to enhance 12 the ROP treatment of crosscutting issues to more fully 13 address safety culture.
14 So, the substantive crosscutting issue 15 process was born. The purpose of the substantive 16 crosscutting issue is to inform the licensee that the 17 NRC has a concern with the licensee's performance in 18 that crosscutting area and to encourage licensees to 19 take appropriate actions before more significant 20 performance issues emerge.
21 Those crosscutting areas in the ROP 22 framework are human performance, problem 23 identification resolution and safety conscious work 24 environment.
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21 Safety conscious work environment is 1
defined to be an environment in which workers feel 2
free to raise nuclear safety concerns without fear of 3
harassment, intimidation, retaliation, or 4
discrimination.
5 Staff conducted an effectiveness review of 6
the SCCI process in 2014. There were several 7
conclusions that came out of that effectiveness 8
review.
9 Of those it's difficult to prove that 10 licensee corrective actions that result from 11 identification of SCCI prevented more significant 12 performance issues from occurring. You can't prove a 13 negative didn't occur.
14 But we did also determine that SCCIs are 15 not a leading indicator for declining licensee 16 performance. At the time there were 86 licensees that 17 had moved right in the action matrix indicating 18 declining performance without exhibiting a substantive 19 crosscutting issue.
20 So consequently a working group was stood 21 up to make some changes to the SCCI process. Those 22 changes are -- the most significant changes are listed 23 here.
24 The original threshold for crosscutting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 theme was four inspection findings for the same 1
crosscutting aspect in a 12-month assessment period.
2 That was pretty low. That means they only 3
needed one inspection finding per quarter with the 4
same crosscutting aspect to what we consider to be a 5
theme.
6 And at the time a crosscutting issue 7
needed two elements. I have a theme and the NRC had 8
to have a concern with the licensee's ability to 9
actually correct that theme.
10 CHAIRMAN BLEY: I have a question.
11 MR. MERZKE: Sure.
12 CHAIRMAN BLEY: I believe the indicators 13 came out. You know, 30 or 40 years ago there was a 14 tremendous amount of effort trying to come up with 15 leading indicators and as far as I could tell to no 16 avail.
17 I've heard rumors that INPO has developed 18 something they think is truly a leading indicator. I 19 don't know if you know anything about it or if you can 20 talk about it if you do, but if you can I wonder if 21 you've heard anything about it.
22 Have you guys given any more thought to 23 leading indicators.
24 MR.
MERZKE:
Actually I
had this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 discussion yesterday with our staff. Not about the 1
INPO leading indicators. First I've heard of it, 2
although I did meet with a representative from INPO in 3
Vienna a couple of months ago. We had a discussion 4
about more what we could do to adjust the baseline 5
inspection program based on INPO evaluations.
6 So there's some work to be done with INPO 7
and what they're doing. And I think we look forward 8
to that.
9 But the leading indicator issue has not 10 gone away. We know that the Commission is always 11 looking for us to find those leading indicators.
12 I will say that I reviewed the ANO-95003 13 lessons learned report recently and that report 14 concluded that the licensee had declining performance 15 over a period of years that was not captured by the 16 ROP.
17 And there were several indicators from 18 which they made that conclusion. So I'm taking a look 19 at those indicators to see is there a performance 20 indicator that we can generate out of those that would 21 be a valid leading indicator of declining performance.
22 CHAIRMAN BLEY: Of course in retrospect 23 you can always come up with something.
24 MR. MERZKE: It's easy looking back.
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24 Maybe there's something there that we can develop.
1 But we're definitely focused on that.
2 VICE CHAIRMAN CORRADINI: If I can go back 3
to conversations with INPO. So they have their own 4
set of evaluations based on operating staff reviews, 5
technician reviews, and they do that on plants on a 6
regular basis.
7 Is there an ongoing conversation with INPO 8
between the NRC and INPO in terms of how they evaluate 9
and how you're evaluating? Because there's a lot of 10 overlap in certain areas.
11 MR. MERZKE: There is overlap but I would 12 not say that there's a regularly scheduled dialogue 13 between the two organizations.
14 We do have different objectives. Ours is 15 to make sure that the licensees operate safely. INPO 16 focuses more on excellence. You know, above and 17 beyond.
18 We do review INPO reports thoroughly when 19 they issue their evaluations. Basically we do that as 20 part of our process and it's formalized in our process 21 in IMC-0305 to review those INPO reports.
22 And that allows us to validate our 23 inspection and oversight processes. Are we seeing the 24 same things that INPO is seeing. If not, why not.
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25 VICE CHAIRMAN CORRADINI: So it's more a 1
review of their reports than some sort of ongoing 2
meeting with them to see are there issues that they 3
see that you see.
4 MR. MERZKE: That's correct.
5 MEMBER POWERS: The heart and soul of 6
INPO's operation is a confidentiality between them and 7
the licensee. And I think that's essential for INPO 8
and if they were conducting conversations with the NRC 9
about the licensee with any frankness that would 10 violate that confidentiality to the point of rendering 11 them useless.
12 VICE CHAIRMAN CORRADINI: Thank you. So 13 the reports are the vehicle.
14 MR. MERZKE: Right.
15 VICE CHAIRMAN CORRADINI: Okay.
16 MR. MERZKE: Okay, so back to the SCCI 17 process. Originally they needed to have a theme which 18 was four inspection findings with the same 19 crosscutting aspect in 12 months.
20 And we had to have a concern that the 21 licensee was not going to be able to correct that 22 concern.
23 In order to help us facilitate that 24 determination whether we were confident that the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 licensee could or could not address the concern there 1
were several questions that were in IMC-0305.
2 For instance, the licensee had not 3
identified or recognized a crosscutting theme affected 4
other areas and had not taken actions to address the 5
theme.
6 Or the licensee recognized the 7
crosscutting theme affected other areas but failed to 8
schedule or take appropriate corrective actions.
9 There were several questions to that effect.
10 Unfortunately the staff found that those 11 were very subjective questions and again were not 12 implemented or interpreted consistently between the 13 regions.
14 So we had some licensees in one region who 15 were getting SCCIs who in another region would not 16 have gotten the SCCI.
17 So in order to fix this the revision that 18 we made to the SCCI process, the first thing we did 19 was we adjusted the crosscutting theme threshold from 20 four findings to six with the same aspect in the 12-21 month assessment period.
22 We did a lot of data analysis. The 23 licensees that we found had demonstrated performance 24 problems, significant performance issues and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 number of crosscutting aspects that they were getting 1
in areas.
2 We found that that threshold of six would 3
have eliminated the false positives we were getting 4
from licensees that really did not have a problem or 5
a performance issue from those that did. So that's 6
why we set the threshold to six.
7 In addition we created a new crosscutting 8
theme level at the area level, the crosscutting area 9
level. And it was created as a backstop.
10 There are 14 crosscutting aspects in human 11 performance area. If a licensee had 5 hits in each 12 one of those aspects they could potentially have 70 13 crosscutting hits in human performance over a 12-month 14 period without ever tripping the theme.
15 So we were like wow, that just would not 16 be right. There's a problem with a licensee that has 17 that many human performance issues.
18 So we set backstop
- levels, human 19 performance level at 20 hits and problem 20 identification resolution with 12 findings during a 21 12-month assessment period.
22 CHAIRMAN BLEY: Dan let me ask your 23 earlier statement in the other way. You did not find 24 that you needed a high number of crosscutting issues 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 to end up in trouble.
1 But did most of the plants that had high 2
numbers of crosscutting issues actually end up in 3
trouble eventually? It doesn't predict for everybody, 4
but for those who are in trouble, that area, does it 5
lead to other problems. Or have you been able to 6
determine that.
7 MR. MERZKE: It's a challenge because 8
licensees that have significant performance problems 9
issues end up getting increased regulatory oversight 10 in the form of supplemental inspections.
11 And when you put more inspectors and more 12 inspection resources into a licensee you're going to 13 find more findings. And those increase the number of 14 aspects you see.
15 So it's very difficult to say the chicken 16 or the egg which came first.
17 CHAIRMAN BLEY: Fair enough.
18 MR. MERZKE: I hope that answered your 19 question.
20 MEMBER SKILLMAN: Dan, I'm going to ask 21 you if you can to complete within 30 minutes please.
22 MR. MERZKE: Sure. I'll give it a shot.
23 In addition we eliminated the term substantive because 24 we determined that that really put a higher hat on an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 issue that may not really have been significant.
1 We eliminated the subjective questions to 2
determine a crosscutting issue existed. And now we 3
basically put the criteria out there. The first time 4
they cross a theme or exceed a threshold for a theme 5
we'll document in an assessment letter.
6 The second consecutive time again we'll 7
document it.
8 The third consecutive time they have the 9
same crosscutting theme then we'll issue a
10 crosscutting issue which formalizes the process and 11 require an inspection to close that issue.
12 The impact of those changes. No licensee 13 has been issued a crosscutting issue to date since we 14 made those revisions.
15 For perspective from 2006 to 2013 269 16 substantive crosscutting issues were identified and 17 documented. It was a lot. A lot of effort was going 18 into this.
19 Two licensees have tripped the revised 20 criteria for a crosscutting theme with six findings in 21 the same crosscutting aspect. They were Fort Calhoun 22 and Pilgrim. Again those two licensees with 23 significant performance issues.
24 Four licensees have actually tripped the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 crosscutting theme at the crosscutting area level.
1 They've hit the backstop either at the human 2
performance or PINR. Again I list those because 3
you'll notice that some of those again have 4
significant performance issues. In the case of Fort 5
Calhoun it's been closed down.
6 And the last bullet, licensees with 7
crosscutting themes are generally plants with 8
performance issues now. We're not seeing the false 9
positives we had before.
10 And also for perspective I looked at all 11 licensees that have had four CCAs based on the old 12 criteria. It's been consistent throughout since the 13 revision six to seven licensees have hit that old 14 criteria, but none of them are getting repeats in 15 subsequent periods.
16 So that indicates that the licensees are 17 fixing their problems, finding them and correcting 18 them, or they didn't have a problem in the first 19 place.
20 The next issue we revised was the 21 definition of degraded cornerstone. The staff 22 submitted a SECY paper 150108 in 2015 recommending to 23 the Commission that we change the definition of 24 degraded cornerstone from yellow input in the action 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 matrix and two white inputs in the same cornerstone to 1
three white inputs in the same cornerstone.
2 We did this for a number of reasons that 3
were delineated or described in the SECY paper.
4 Basically there was no technical basis for two white 5
inputs resulting in a licensee being in a degraded 6
cornerstone, or that two white inputs was equivalent 7
to one yellow input.
8 We did a probabilistic risk assessment and 9
that concluded that three white inputs was more 10 equivalent to a yellow input.
11 The Commission agreed with us and 12 subsequently approved our recommendation. And in 2016 13 we made that change to the process.
14 And to date no licensee has met the 15 revised definition of degraded cornerstone nor has any 16 licensee met the original definition of degraded 17 cornerstone.
18 We had not had a licensee in column three 19 of the action matrix since Pilgrim in 2014 which is a 20 long period of time for no licensees in column three.
21 But again, no licensee met the original 22 criteria of two whites in a cornerstone. So it might 23 indicate that the licensee's performance is actually 24 improving.
I mean that's just a
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32 observation.
1 MEMBER REMPE: So I am slow but I've been 2
puzzling on it on slide 9. You did a PRA that 3
concluded three white inputs are needed to cross the 4
threshold.
5 What kind of PRA and what was the --
6 MR. MERZKE: We took average risk delta 7
CDFs, delta core damage frequencies. I pulled the 8
risk analysis.
9 MEMBER REMPE: For a particular plant?
10 MR. MERZKE: If you go back to the 11 original development of the ROP the recommendation was 12 as many as five whites would be equivalent to a yellow 13 at the time.
14 And a conservative decision was made by 15 management to make it two.
16 MEMBER REMPE: It was based on a 17 particular plant?
18 MR. MERZKE: Not on a specific plant, but 19 in a generic, in this case an average white finding 20 was change of core damage frequency of 5E-6. If you 21 get two 5E-6's basically you've got the 1E-5 but that 22 was still -- that didn't cross the threshold for 23 yellow.
24 So even with another -- you're just barely 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 crossing the threshold of yellow.
1 CHAIRMAN BLEY: We actually had a series 2
of meetings with you on this and wrote a letter on 3
this a couple of years ago.
4 MEMBER SKILLMAN: This is where the DPO 5
issue came up and we met with the author of the 6
differing opinion and we ended up writing a letter on 7
it.
8 MR. MERZKE: It was not a change that was 9
accepted by many of the regions. As a matter of fact 10 only one region actually agreed with the proposal.
11 So it was controversial but the Commission 12 basically agreed with the staff.
13 The last topic I have to share with you is 14 the timely resolution of inspection findings. This is 15 an ongoing initiative at this time to improve the 16 timeliness of significance determinations for 17 potentially greater than green findings.
18 Basically it's taking a long time for an 19 event to occur and for the staff to develop the final 20 significance determination that moves the licensee to 21 a different column of the action matrix.
22 I think some studies have been done where 23 as many as 30 percent of greater than green inspection 24 findings were taking over 365 days to resolve.
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34 There's always a balance, it's a very 1
delicate balance between coming up with the right 2
significance determination, the correct one, and doing 3
it in a timely fashion.
4 So licensees don't always agree with our 5
assumptions and there's a lot of back and forth 6
discussion over those assumptions. It sometimes takes 7
a lot of time.
8 And sometimes licensees are asking us for 9
more time in order for them to do testing to 10 demonstrate that a degraded component could still 11 fulfill its safety function when we thought it could 12 not.
13 So some of these things just end up taking 14 a long time.
15 ANO brought this to a head with the stater 16 drop and it took well over a year for the staff to 17 finally conclude that the significance of the event 18 was a yellow and moving them to column three at the 19 time, and then the second yellow moved them to column 20 four.
21 So the staff has implemented this new 22 process. It's called inspection finding resolution 23 management. And it's been ongoing through this year 24 and we'll be -- I think the piloting will be completed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 at the end of the year.
1 The staff will do an effectiveness review 2
in 2018.
3 Basically an inspection finding review 4
board is stood up for potentially greater than green 5
findings to get alignment with stakeholders early in 6
the process to determine what the exact performance 7
deficiency is and the path forward to get that 8
significance done in a timely fashion.
9 We also added a metric to the ROP self-10 assessment process from the time an event occurs to 11 the time we make a determination or lock down the 12 performance deficiency is the start of the official 13 STP process of 120 days.
14 And to date we've had eight significance 15 determinations meet that 120-day metric. Five still 16 have not.
17 There's some very complicated issues out 18 there which take some time. So we don't expect 100 19 percent.
20 But it's ongoing and there will be an 21 effectiveness review in 2018 to determine if this 22 process is viable and working.
23 MEMBER BALLINGER:
Who are the 24 stakeholders? Are there any external stakeholders?
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36 MR. MERZKE: No external stakeholders on 1
the finding review board. But there's significant 2
interaction with the licensees, especially with their 3
PRA folks in the development of the performance 4
deficiency and the initial significance determination.
5 That's it for the assessment process. I'd 6
like to turn it over to Jim now and he can talk about 7
what's going on with the engineering inspections as 8
our final topic.
9 MEMBER SKILLMAN: Please do. Thank you.
10 MR. ISOM: Good morning, my name is Jim 11 Isom. I work with Dan in NRR DRS. And the inspection 12 program. And I am on slide 12.
13 So the purpose of me talking to you all 14 today is to bring you up to date since I guess we 15 briefed you last October 2015, our ROP enhancement 16 efforts Dan mentioned.
17 ROP enhancement efforts started in 2012.
18 The report was issued 2014. I came in towards the 19 tail end of that project and I was tasked with making 20 the changes per the ROP enhancement recommendations to 21 one particular procedure. It's called a component 22 design basis inspection. People usually call it CDBI 23 inspection procedure.
24 In the letter it mentions a couple of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 other programs and I'm only discussing the CDBI aspect 1
just to let you know where this is headed.
2 One of the recommendations we had from the 3
enhancement effort and also from our lessons learned.
4 We do have a lessons learned for every 95003 or every 5
plant that gets a finding was that we as NRC should 6
look at licensees' implementation of some key 7
engineering programs.
8 MEMBER SKILLMAN: It would probably be 9
helpful if you just took a minute and explained what 10 a 95003 inspection is.
11 MR. ISOM: Okay. So if there is a risk 12 significant finding which is the red we do a very 13 comprehensive root cause evaluation inspection that's 14 typically just called a 95003 but it's basically a 15 root cause inspection by us to verify the licensee 16 actually has the organization and ability to identify 17 and correct significant conditions of adverse quality.
18 So like Dan said it's a very resource-19 intensive inspection. It takes many, many months to 20 complete. So that's what a 95003 is.
21 MEMBER SKILLMAN: Let's go a little bit 22 further for the members. So a 95003 normally involves 23 I'm going to say 16 to 24 inspectors onsite for two 24 weeks. They disappear for a writing period and they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 come back maybe four weeks later.
1 And so when a licensee finds himself in 2
95003 that licensee is one step away from having the 3
keys taken away.
4 So when we talk 95003 we are talking 5
millions of dollars and the licensees are commonly not 6
able to conduct this inspection or respond to the 7
inspection by themselves. They normally must bring in 8
many contractors.
9 So when Jim talks about 95003 this is not 10 an afternoon affair. This is an affair that will go 11 on for approximately six months and maybe longer.
12 There might be corrective action letters, CALs, 13 confirmatory action letters.
14 So when Jim and Dan talk about 95003 this 15 is basically getting slugged with a baseball bat in 16 the back of your head. This is the ultimate wake-up 17 call because the next step is to lose your keys.
18 Davis-Besse 0350. You're literally not able to 19 operate.
20 So 95003 is the consequence of a 95001 and 21 a 95002 and whammo there's 95003. It is extremely, 22 extremely serious.
23 I'm not sure that the members if they 24 hadn't been through it might not appreciate just how 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 impactful that is.
1 MR. ISOM: They're one column away from 2
being shut down.
3 MEMBER SKILLMAN: You're one column away 4
from being shut down. The next item if it's a 5
significant finding may put you in 0350.
6 MR. ISOM: So one of the results of 7
internal lessons learned from one of our 95003 had to 8
do with a stem and disc separation in the power 9
plants. That was a red finding. It was a fire 10 protection issue but had a major impact on reactor 11 safety.
12 And from that internal lessons learned we 13 were requested that we do a staff review where we 14 should inspect the licensees and key engineering 15 programs like MOV program, equipment qualification 16 program, commercial weight dedication program.
17 So in early 2015 we decided that's a good 18 recommendation. We're going to take that on and we're 19 going to put that in the CBDI inspection procedure.
20 And we convey our intentions with the 21 industry in early 2015 and they engaged and one of the 22 feedback we received was the CDBI is too resource 23 intensive. We've been doing this in one form or 24 another since 2000.
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40 We have inspected all the risk significant 1
components at least once at most of the power plants.
2 So can we do a more efficient form but still be 3
effective.
4 And so what we did in calendar year 2015 5
and 2016 is we piloted a shorter version of CBDI. It 6
was a two-week version. Two weeks onsite version 7
versus three weeks onsite.
8 And we separated the program 9
implementation inspection. And the first program we 10 chose was equipment qualification which put that out 11 of the CDBI inspection and we called it a different 12 inspection activity.
13 And that was a one-week inspection 14 activity. And we piloted those inspection activities 15 two per region so in calendar year 2015 and 2016.
16 We took the lessons learned from those 17 pilot inspections, we made changes to our inspection 18 procedures and starting this year we have implemented 19 a shorter version of the CDBI. We have renamed it and 20 we named it design basis assurance inspection. And 21 that was to emphasize that what we want to do is --
22 and those are the two IEPs that I'm talking about.
23 21M is design basis assurance inspection. It's 24 basically a successor to the old CDBI inspection 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 program in two-week format.
1 We renamed it to emphasize to the 2
inspectors that we want to make sure that the design 3
basis is maintained. We don't want the inspector to 4
challenge the original design basis, but make sure 5
that the changes are being made adequately.
6 And then 21N is the program implementation 7
inspection. The first program we are looking at this 8
year is equipment qualification or EQ program or 5049 9
rule.
10 And so the plan with the program 11 inspections, we're going to do it once at all the 12 power plants in the U.S. during the tri-annual cycle.
13 So ROP has tri-annual, bi-annual and 14 annual cycle. We're in one of the tri-annual cycles 15 now so 2017, '18, '19, those three years we'll look at 16 how licensees are implementing their EQ program at all 17 the sites in the U.S.
18 In order to make those changes to the 19 original CDBI procedure one of the feedback we got 20 from the piloting inspection was the inspectors told 21 us they could not perform the EQ inspection in one 22 week. Just the breadth was too much.
23 So we said okay, let's make it two weeks.
24 But in order to make it two weeks we had to take a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 resource away from another inspection activity because 1
we were trying to make it a resource neutral activity.
2 So we reduced the scope of one of the 3
other engineering inspections called IEP 71117-T. It 4
was basically, it's a two-week inspection which we 5
look at mods and 5059 evaluations.
6 So we made that a one-week inspection and 7
made the EQ inspection to a two weeks inspection.
8 And we got some feedback from the region 9
saying we made the 17T procedure ineffective because 10 really when you look at modifications the mods in the 11 5059 evaluation, that should go together. It just 12 makes sense to do it together and we acknowledged that 13 was a shortfall of the change.
14 But in order to implement the EQ 15 inspection we had to take the resources somewhere. So 16 that conversation, the engineering effectiveness 17 efficiency review which we are currently in, sometimes 18 people call it the holistic engineering review.
19 We said okay, why don't we look at all the 20 engineering inspections that the regions perform, the 21 region-based inspectors. Let's see if we can identify 22 redundancies, inefficiencies built in, or IPs that 23 were really not effective. Let's do it better. And 24 we told them we'd be doing that.
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43 And on this website is our charter as well 1
as all the correspondence and comments we have 2
received from the industry.
3 So these are the procedures that we are 4
looking at and the scope of the review. So they're 5
pretty comprehensive.
6 Now we know some of these are not 7
effective inspection activities like the ultimate heat 8
sink performance inspection which is 07. That's the 9
inspection where we send one inspector out there to 10 the site to look at, make sure the licensees are 11 making the ultimate heat sink performance in 12 accordance with the design.
13 That's a worthwhile inspection to perform 14 but in the current format it's not really producing a 15 whole lot of issues or findings maybe because the 16 licensee is also maintaining the ultimate heat sink in 17 a good manner.
18 So that's one of the procedures we want to 19 modify or make it part of the example of the 21M 20 procedure design basis assurance team inspection.
21 And then the other thoughts are -- other 22 aspects we're considering is can we change the 23 inspection frequency of some of the activities, for 24 example, fire protection and the DBA inspection down 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 to every three years. Is there any reason we can't do 1
a four or perhaps even five to ensure more 2
flexibility.
3 And some of the other areas we're having 4
internal deliberations on, discussions on is fire 5
protection. For most plants that have adopted NFPA-6 805 we understand that makes the plant much safer by 7
going through that process.
8 So our current thinking is maybe once we 9
inspect the implementation of that license amendment 10 we would stop inspecting NFPA-805 plants. And that 11 would encourage those facilities that have not 12 transitioned to 805 to make that transition. So those 13 are the kind of discussions we're having.
14 And we have actually developed like eight 15 or nine options that deals with all these six 16 inspection procedures. We developed them in June of 17 this year. We discussed them and shared them with our 18 management.
19 Currently we have whittled that down to 20 four recommendations. It hasn't been made public yet 21 but it will be made public next month when we meet 22 with industry.
23 So our view is that once we get comments 24 from industry -- we're also having a meeting next week 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 with industry on the same topic, on this topic to get 1
their additional comments and the members of the 2
public additional comments.
3 And then based on the feedback that we 4
have we're going to finalize our recommendations, make 5
recommendations internally to our senior management 6
within NRC to get their buy-in.
7 Once we get their buy-in we plan to write 8
a Commission paper in the summer of 2018 making 9
recommended changes to the engineering inspection 10 procedures and activities and ask for their approval 11 for the change.
12 So here are some of the meetings that we 13 have. Next one coming up is next week. It's December 14 12 and industry.
15 One of the things industry wants us to do 16 is they want us to give themselves credit for licensee 17 self-assessments.
18 They do them anyway to prepare for 19 inspections so their view is is it possible for us to 20
-- if they do a good enough self-assessment can they 21 give us credit for one of our inspection activities or 22 maybe more. It's not clear exactly what they want.
23 But that's the concept anyway.
24 This is the conceptual stage. We agree 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 with them conceptually but we need to go through all 1
the details like to what standards will you do the 2
licensee self-assessment.
3 Who does them to make sure they're 4
independent and they're quality like NRC inspectors 5
would do. And so we're evaluating that.
6 And that's probably a little bit more 7
long-term project rather than this effectiveness and 8
efficiency review which we're planning to complete, to 9
wrap up sometime next year.
10 So most of the comments received from the 11 public on the licensee self-assessments have not been 12 positive. They don't think we should cut back on our 13 inspection effort and give them credit for licensee 14 self-assessment.
15 So a lot of the comments are coming from 16 areas in the Northeast around Pilgrim. So just to let 17 you know.
18 And we're posting the comments on the 19 public webpage on the proceeding page.
20 MEMBER SUNSERI: I suppose one of the ways 21 you could address that is have an inspection like the 22 resident inspector or augmented inspector come down 23 and observe that self-assessment.
24 MR. ISOM: Yes. Right. If we approved 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 the licensee assessment inspection procedure we would 1
do exactly what you said. And that would validate 2
that it was done in a quality manner.
3 MEMBER BALLINGER: You mentioned Pilgrim.
4 Is that an aberration? Well, Pilgrim --
5 MEMBER STETKAR: Is it unique perhaps.
6 MEMBER BALLINGER:
Unique and an 7
aberration.
8 Because Pilgrim has been in -- I could use 9
different words, deep yogurt for some time now.
10 MR. ISOM: I think they're unique I would 11 say.
12 MEMBER BALLINGER: Okay. Because there's 13 a cadre of people or whatever you want to call it at 14 Pilgrim that as soon as Pilgrim disappears as a 15 problem they find another place.
16 MR. ISOM: Yes, there is an anti-nuclear 17 element out there. We acknowledge that.
18 MEMBER RICCARDELLA: I want to ask a big 19 picture question. If one of these engineering 20 inspections were performed at the Fukushima plant 21 before that 211 incident do you think it would have 22 come up with any findings?
23 MR. ISOM: Oh yes. I have confidence in 24 our inspections and our contractor staff. We would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 have questioned some of the issues like why are some 1
of your breakers below flood level. Issues like that.
2 MEMBER RICCARDELLA: Yes, I guess it had 3
to do with really I think the design basis external 4
events.
5 MR. ISOM: Right.
6 MEMBER RICCARDELLA: And were they 7
sufficient or not.
8 MR. ISOM: Yes. We looked at that. We 9
challenged the design basis even though we may have 10 approved them if they don't think we're incorrect we 11 will challenge that. And if we have to go through 12 backfit we will go through that process.
13 MEMBER RICCARDELLA: Thank you.
14 MEMBER STETKAR: How do you handle things 15 like manmade hazards that evolve over time?
16 MR. ISOM: Like -- and things like that?
17 MEMBER STETKAR: Like somebody built a 18 munitions plant next to my nuclear facility that 19 wasn't there when I was originally licensed. For 20 example.
21 MR. ISOM: That's not within the scope of 22 the design basis assurance inspection. But those are 23 the kind of issues that we expect the resident 24 inspector to raise when we come to the site like are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 there any issues that you have that we need to look 1
at.
2 MEMBER STETKAR: Well then how would you 3
-- in answer to Pete's question how would you then 4
raise a concern about flooding at Fukushima where the 5
plant was licensed and it was well within its design 6
basis?
7 MR. ISOM: Because we -- as part of our 8
review if for example flood protection was chosen as 9
an inspection sample.
10 MEMBER STETKAR: They had all the flood 11 protection in the world for their design basis.
12 MR. ISOM: Yes, but we would say okay, 13 what's the basis for the flood height of the wall.
14 Where is that coming from. So we would have questions 15 like that.
16 MEMBER STETKAR: But you don't look at the 17 munitions plant next door because that's not within 18 your scope. I don't get it, quite honestly, and it's 19 not clear to me you would raise the flag at Fukushima 20 for their design basis flooding.
21 You didn't raise flags at U.S. plants for 22 their design basis flooding when they had flood 23 problems until plants had flood problems or Fukushima 24 was flooded. Let's be honest.
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50 MR. ISOM: Okay, so I'm not sure --
1 MR. BOWMAN: At Calhoun we did raise 2
inspection --
3 MEMBER STETKAR: After they had the flood.
4 MR. ISOM: For Calhoun we raised the issue 5
before the flood.
6 CHAIRMAN BLEY: You need to get your name 7
on the record.
8 MR. BOWMAN: Greg Bowman.
9 MR. ISOM: So I can send you information 10 on that. We raised it as part of the CDBI. One of 11 the contractors walking down our system says wait a 12 minute, this piping that's coming through this wall 13 that goes to the safety-related room, the flood 14 barrier had deteriorated or missing. And I know it's 15 below flood grade. And he knew that because he worked 16 under the --
17 MEMBER STETKAR: That was before the 18 flood.
19 MR. ISOM: Yes.
20 MEMBER STETKAR: Okay, thanks. I wasn't 21 aware of that.
22 MR. ISOM: That was an unresolved item 23 from that. And the region followed up on that and 24 they said wait a minute, there are other issues out 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 there.
1 And so based on the CDBI effort that 2
resolved, eventually it ended up in a yellow finding 3
before the flood.
4 CHAIRMAN BLEY: Jim, I'd like to pursue 5
John's -- I'll stay with the munitions factory because 6
why not. Let me go ahead with this. Because we've 7
been talking about this with people for a number of 8
years here.
9 I also don't get why this shouldn't be 10 part of the design basis inspection. And kind of all 11 we ever hear is well, either the resident or the 12 licensee will notice this and tell us.
13 It seems way too vague for something that 14 could potentially be a significant new problem at a 15 site.
16 Have you guys actually thought about this?
17 Where does this belong in the regulatory structure?
18 I don't think you can cite to me anything 19 that requires the licensee to tell you. I don't know 20 there's anything that guides the site inspector to 21 tell anybody.
22 Good sense would do that, but it seems a 23 real gap in the things we look at.
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52 subtle things. I use the munitions factory as 1
obviously something that people ought to recognize 2
being built.
3 But there are things, for example if you 4
have a regional airport that expands over the course 5
of years their traffic and the types of air traffic 6
that they have such that they're now handling a much 7
larger number of flights and a different mix of 8
aircraft that have different crash frequencies and 9
things like that.
10 They expand the local highways such that 11 they become a four-lane major thoroughfare that's 12 handling a heck of a lot more truck traffic with 13 hazardous materials, or our rail system isn't really 14 expanding these days but you can also use rails.
15 Those also would challenge the original 16 design basis of the plant which is based on estimates 17 of frequencies of numbers of aircraft takeoffs and 18 landings, numbers of traffic of specific types of 19 materials.
20 And from what we've heard those are never 21 challenged.
22 MR. ISOM: That's correct. That's not 23 within our baseline inspection program scope.
24 MR. BOWMAN: So I think John -- this is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 Greg. We can take that back as something to look at 1
as part of this.
2 I think you're all aware we had all the 3
work on recommendation 2.2 where this came up 4
previously. So we did assess it at that time.
5 But we can certainly take back the concern 6
and see if -- personally I don't believe that the 7
design basis assurance inspection is the right place 8
for that kind of look because I think you're really 9
looking at whether new information would cause us to 10 backfit a license.
11 I think that's a bit beyond the scope of 12 their inspection. But I would tend to agree with you 13 that there ought to be some --
14 CHAIRMAN BLEY: There ought to be 15 somewhere.
16 Now we recommended when you were setting 17 up the center for excellence for external events that 18 you include human-induced events and we were told no, 19 we don't need to do that.
20 It ought to be somewhere. It really 21 should.
22 MR. ISOM: But just to kind of defend the 23 DBA inspection program a little bit it's focused on 24 ability of the mitigation system to function properly 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 once an event occurs.
1 So to your point we look at increased 2
frequency of external events, initiating events which 3
might drive you to that --
4 MEMBER RICCARDELLA: It just seems like if 5
you're going to review design basis adequacy and 6
demonstrate design basis adequacy you ought to do it 7
as if the plant were being licensed today. Shouldn't 8
you?
9 CHAIRMAN BLEY: Well, I'll take you back 10 to Fukushima. It wasn't when the plant was first 11 designed at least from my understanding that most 12 people over there understood quite the risk of 13 tsunami. But over the years it became clear that 14 there had been tsunamis this big and there's a long 15 history of identifying where they'd come.
16 And sometime over that period it would 17 have been reasonable to say we know more now and the 18 design basis ought to change.
19 But given what you just said I'm not sure 20 how that would have been picked up if it were here.
21 MEMBER REMPE: Didn't we hear from Dick's 22 research review that the staff is working with USGS 23 and EPRI to do some sort of partial review.
24 Although they're not taking over the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 burden from the licensee to update their design basis 1
threat but they're going to be monitoring that.
2 I thought that was --
3 CHAIRMAN BLEY: For external events.
4 That's what the center of excellence is supposed to be 5
doing.
6 MEMBER REMPE: It won't cover munitions 7
factory but for some of the external events --
8 CHAIRMAN BLEY: It won't do anything 9
that's manmade.
10 MEMBER REMPE: Yes, right.
11 CHAIRMAN BLEY: On purpose. And we don't 12 know how well it's going to do the other but we will 13 certainly check up on it.
14 MEMBER SKILLMAN: To the exact point that 15 John and Dennis raised I recall when we were writing 16 our letter on 2.2 we identified this and got feedback 17 on our discussion of how the plants would be 18 interacting with the local community to stay abreast 19 of changes that might present an external threat.
20 CHAIRMAN BLEY: That seemed more of a hope 21 than a requirement to me.
22 MEMBER SKILLMAN: But I believe we made a 23 recommendation along those lines.
24 CHAIRMAN BLEY: Oh yes.
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56 MEMBER SKILLMAN: So we've not been silent 1
on this. But I think the lens is becoming thicker and 2
our clarity is getting better asking that this be 3
acted on. And that's what we're hearing here.
4 MEMBER REMPE: Could I ask a different 5
question?
6 MEMBER SKILLMAN: Sure. I'd like to be 7
mindful of time because Derek and I have some good 8
stuff for you.
9 MEMBER REMPE: But one thing I haven't 10 heard you guys discuss today is what's happening with 11 the direction the commissioners gave you to take the 12 SAMGs and review them as part of the ROP.
13 And I know we've discussed that in the 14 past. It's been over a year since we've asked you 15 what's happening on that.
16 MR. BOWMAN: This is Greg Bowman of DRS.
17 I think this is -- it's not these guys who are doing 18 that. We can get back to you with more information.
19 I don't think we have the right people in the room 20 here to answer that.
21 MEMBER REMPE: I'm just curious on what's 22 happening.
23 MR. BOWMAN: We've been doing work to --
24 I risk giving you information that's not entirely 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 accurate. So we'll get back to you on that.
1 But we have been doing work to update 2
inspection procedures to first ensure that the SAMGs 3
are updated to the owner's group guidelines and then 4
establish on a periodic basis that as they're updated 5
in the future that those updates are reflected in 6
site-specific SAMGs.
7 So those are things that we're putting 8
into existing inspection procedures. I don't have a 9
status update on that. That's not something the three 10 of us are directly involved in. I'm just semi aware 11 from my time in JLD.
12 MEMBER REMPE:
Because
- yes, my 13 understanding is that there's generic stuff coming out 14 of the owners groups but they really need to have 15 plant-specific implementation.
16 MR. BOWMAN: And the generic guidance for 17 the PWRs was a couple of years ahead of that for the 18 BWRs just because of the work the BWRs were doing on 19 the hardened vent that feeds into the SAMGs.
20 So there was sort of a staggered timeline 21 for the two different types of reactors. I'm just not 22 exactly sure where things are with that. I haven't 23 gotten a recent update.
24 MEMBER REMPE: Okay, thank you.
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58 MEMBER SKILLMAN: Jim and Dan, thank you 1
very much. I would like to present one idea. I'm 2
going to ask my colleagues to do the same if they wish 3
to for the information you've presented.
4 When you mention that you're going to look 5
at the 95003 inspection for ANO in the lessons and the 6
discovery at some level that there had been lingering 7
issues for years that might lead to a discussion 8
regarding leading indicators.
9 I for one would like to hear about that.
10 But I would like to suggest that with the experience 11 that exists around this table perhaps a discussion 12 about what we think, members think individually about 13 leading indicators might be a
very fruitful 14 discussion.
15 Between those of us around the table we've 16 got a lot of insights based on the journeys that we've 17 all had in our careers.
18 And there might be some value in an 19 information briefing with a couple of hours of 20 discussion. We've got individuals who've run plants, 21 been in executive positions for plants, been deep in 22 the bowels of the plants for years who went from the 23 SALP to the ROP and who know industry the lingo and 24 maybe where the skeletons are.
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59 And that information might be very useful 1
in trying to put together some leading indicators.
2 MR. MERZKE: Yes, sir, I agree. I think 3
your experience and knowledge would be invaluable in 4
developing an indicator like that.
5 MR. BOWMAN: This is Greg Bowman of DRS.
6 We'll work with Derek to get on your calendar at some 7
point. I think we would get a lot from your insight.
8 Talk about what we're thinking, what you're thinking.
9 MEMBER SKILLMAN: And I'm going to suggest 10 first quarter of 2018 because we might be losing key 11 members and the insights from those members may be 12 particularly valuable.
13 MEMBER RAY: Dick, I apologize to 14 everyone. I had to go to the badging office at 9 15 o'clock and I missed the discussion that just 16 occurred.
17 But looking through the presentation and 18 piggybacking on what you just said I didn't see any 19 reference to a performance in accordance with appendix 20 B as being a leading indicator.
21 And yet it's one of the most --
22 MEMBER SKILLMAN: Critical.
23 MEMBER RAY: Well critical, or it's one of 24 the things that you can look at in advance of bad 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 things happening and see the requirements of that 1
regulation aren't being met.
2 And inevitably I think it leads then to 3
other problems that concern us in terms of 4
consequences.
5 So that would be my addition to what Dick 6
just said is in my experience and I've as he said had 7
a lot of it if somebody disregards the requirements of 8
appendix B where they apply they often are not looked 9
at. The owners groups don't like it to be looked at 10 because they feel it's not significant unless it has 11 consequences.
12 I think it's significant as a leading 13 indicator.
14 MR. ISOM: Thank you.
15 MEMBER SKILLMAN: I concur with Harold and 16 I add to that work management and material condition 17 of the plant, enforcement of maintenance rule. Put 18 those together I think you've got the indicators you 19 need.
20 With that --
21 CHAIRMAN BLEY: Since we're getting on the 22 record with our thoughts on this thing -- but they're 23 from individual members I move to say a lot of -- I've 24 seen over the last 40 years a lot of fairly smart 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 people and experienced people give this a whirl.
1 Every one of the ideas they came up with 2
sounded pretty reasonable. And not one that I've seen 3
has really proved out as a genuine leading indicator.
4 So some care is required before we move forward.
5 MEMBER SKILLMAN: Thank you, Dennis. Jim 6
and Dan, you're completed with your task. You're 7
welcome to stay for the information that Derek and I 8
will --
9 MR. MERZKE: Thank you for the invitation.
10 MEMBER SKILLMAN: With that I'm going to 11 transition to the slide package that you have in front 12 of you and Derek's going to operate the slides and 13 we're going to jump right into this because we've only 14 got about 50 minutes remaining.
15 CHAIRMAN BLEY: If Derek does a slide a 16 minute he might get close to done.
17 MEMBER SKILLMAN: Slide 2. Dan explained 18 this earlier. Notice at the bottom the crosscutting 19 areas, the three human performance, BNIR, and safety 20 conscious work environment. Those three were born out 21 of the Davis-Besse head event in 2002.
22 The cornerstones that we learned to live 23 with, this is the -- if you will the replacement of 24
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62 performance. This is the new ROP from about the year 1
2000 and the cornerstones are initiating events, 2
mitigating systems, barrier integrity and emergency 3
preparedness.
4 Notice that the four greens feed reactor 5
safety. The two yellows or oranges, the public 6
radiation occupational radiation are the radiation 7
safety. That's really 10 CFR 20.
8 And then security, the blue on the right 9
is safeguards. An awful lot of that information is 10 SUNSI but that's the protection of the plant.
11 All of the information from those seven 12 cornerstones feed to the three key areas of reactor 13 safety, radiation safety and safeguards and ultimately 14 to the mission of the NRC which is to protect the 15 public.
16 So the reactor oversight process is 17 focused on these major themes. Next slide.
18 At a very basic level each of the 19 cornerstones has its own assessment. And those 20 assessments are conducted with the residents onsite 21 and they're in their supplemental inspections, the 22 event reports and so on.
23 Those feed up to the enforcement block, 24 the assessment process. I would just make this one 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 comment. When there is a finding very often the site 1
or the people at the site communicate with the region.
2 And the people at the sites are normally 3
in contact with their own PRA experts within the 4
utility. And those PRA experts will communicate with 5
the region PRA resource.
6 And between those two if there's an 7
emergent issue at the plant the site people and the 8
region PRA people will discuss what is the 9
significance of this.
10 And that really begins the process of what 11 have we found, what does it mean, and what do we do 12 with it. Next slide.
13 How many plants are in the target? It's 14 101. This is calendar year 2015 and 2016. We had a 15 couple of plants fall off. But basically it's 101 and 16 that includes Watts Bar 2. It's really 100 plus 1 so 17 it's 101.
18 So region 1, that's the northeast part of 19 the country and the center for that is King of 20 Prussia, Pennsylvania.
21 Region 2 is down in Atlanta. Region 3 is 22 out of Chicago. And region 4 is where we visited in 23 Dallas.
24 So for these colors, green. Charlie, you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 asked about green. This is the risk assessment for 1
green.
2 They find a finding so say it's us at the 3
site. We say goodness gracious, it's a feedwater 4
item, it's a feedwater valve that's been isolated.
5 What's the CDF assigned to that particular event.
6 They do a review and you say golly, it's 7
less than 10-6 it's green. Or you might say it is a 8
closed suction valve for decay heat removal. That 9
might bump you up into white where for that time 10 period for that event you have a CDF that's between 11 greater than 10-6 and less than 10-5. And so it goes.
12 If you find holy smoke all of your ECCS 13 disabled for nine months and you didn't realize it 14 you're probably up in red.
15 So it's a graded approach for the color of 16 the finding. But there's a surprise.
17 Green is a
finding of very low 18 significance. Greater than green is a security event, 19 but its color is not described. The greater than 20 green security could be yellow, red, or white. But 21 for SUNSI reasons the security event color is not made 22 public. So there are really five categories. Green, 23 greater than green, white, yellow and red.
24 And in all cases the color is based on the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 delta LERF and delta CDF that's on the prior slide.
1 VICE CHAIRMAN CORRADINI: Not for blue.
2 MEMBER SKILLMAN: There's no blue.
3 VICE CHAIRMAN CORRADINI: There's a blue 4
greater than green.
5 MEMBER SKILLMAN: That's called greater 6
than green.
7 VICE CHAIRMAN CORRADINI: It's blue on the 8
screen. What about that? That's not a risk 9
calculation.
10 MEMBER SKILLMAN: Yes, sir. It is.
11 VICE CHAIRMAN CORRADINI: It's not 12 calculable because if it is then -- I thought it 13 wasn't calculable. It wasn't being calculated.
14 MEMBER SKILLMAN: You are accurate, sir.
15 No argument. That will be an assessment for the 16 significance of that finding greater than green.
17 All right. 2015. We're reaching back 18 because the data is trailing data. Okay, how many 19 reds were there and in which of the seven 20 cornerstones.
21 And there are the data. You can see --
22 you just might kind of keep in mind about how many 23 findings there are because this is relatively 24 consistent from 2015 into 2016.
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66 The industry seems to have a cadence and 1
it kind of follows that cadence.
2 Notice that the greater than green were 12 3
in 2015 and there are the data.
4 Notice in '16 greater than green was four, 5
significant decrease in the security greater than 6
greens.
7 And the other numbers are at approximately 8
the same order of magnitude.
9 MEMBER KIRCHNER: So Dick, I noticed just 10 looking quickly at the material you've given us most 11 of the findings appear to be in initiating events, 12 mitigating systems. So what is that telling you? In 13 terms of trends and such.
14 MEMBER SKILLMAN: It tells me that the way 15 the inspections are being conducted and --
16 MEMBER KIRCHNER: That's a leading 17 question.
18 MEMBER SKILLMAN: It tells me that the 19 inspectors are down in -- probably in mitigating 20 systems it's probably design issues relating to 21 hardware. Initiating events is probably perhaps 22 operating procedure type issues. You'd have to get 23 into the inspection details to really if you will give 24 the forensics for why the numbers are what they are.
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67 For calendar year '15 and '16 at Arkansas 1
1 and 2, the pair, there are two each for initiating 2
events and for mitigating systems and one event at 3
Oyster Creek in 2015, mitigating systems. There will 4
be some details to follow.
5 MEMBER STETKAR: But in a sense those 6
aren't -- the ANO things aren't four separate events 7
aren't they? It's one thing that gave them two yellow 8
findings at each unit.
9 MEMBER SKILLMAN: And they carried it two 10 years.
11 MEMBER STETKAR: Yes. But I mean it's 12 just been carried through. It's not as if four things 13 have cropped up separately in Arkansas. It's a 14 continuation of the yellow findings from that state.
15 MEMBER SKILLMAN: What it is is as Dan 16 said earlier once they got into the inspections they 17 found more issues related to those two events.
18 MEMBER STETKAR: They found flooding 19 issues. They found offsite power.
20 MEMBER SKILLMAN: That's correct.
21 MEMBER STETKAR: But it's all derived from 22 that single event.
23 MEMBER SKILLMAN: That's correct.
24 MEMBER STETKAR: At both units.
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68 MEMBER SKILLMAN: At both units.
1 MEMBER STETKAR: What I'm trying to make 2
a point is at Oyster Creek it's one event.
3 MEMBER SKILLMAN: That's correct.
4 MEMBER STETKAR: This is not necessarily 5
four separate events.
6 MEMBER SKILLMAN: They are related to the 7
original event.
8 MEMBER STETKAR: This is bookkeeping in 9
terms of tracking stuff over two years.
10 MR. WIDMAYER: Well and not only that, but 11 if Dick had asked me okay, rather than make a chart of 12 the number of plants make a chart of the actual number 13 of findings I can't do it. I mean there's lots of 14 them.
15 MEMBER SKILLMAN:
We'll get into 16 permutations and combinations and derivatives of one.
17 But in a way you're right, John. For the 18 two events at Arkansas 1 and 2 those were actually 19 four. And the ones in '16 are derivatives of the 2014 20 drop.
21 MEMBER STETKAR: Just because it's a 22 public meeting I'm trying to make the point that 23 counting up things, you can be misled if you say 24 Arkansas Nuclear 1 has had four events in two years.
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69 It's not that. It had one event that the regulatory 1
oversight process is now tracking as two findings at 2
each of two units and they've stretched out over time.
3 MR. WIDMAYER: Thus the follow-on slides.
4 MEMBER SKILLMAN: Let's proceed because we 5
tried to clarify that. This is historic. The 6
standard drop was early in '14 that resulted in the 7
flooding and the loss of offsite power. This placed 8
Arkansas into column four. And they planned to do a 9
95003. So this is historic.
10 MEMBER RICCARDELLA:
It's kind of 11 interesting. Getting back to what Harold said about 12 QA. The standard drop was clearly a quality assurance 13 problem. They had a bad engineering calculation that 14 wasn't strong enough.
15 But if you hadn't had that the inspection 16 wouldn't -- the normal course of inspections wouldn't 17 have turned up these other things. It's somewhat 18 serendipity.
19 MEMBER SKILLMAN: That's why Dan said when 20 they did the 003 they discovered that there were 21 longstanding years before problems at that site.
22 Hence the question about leading indicators.
23 That's I think what was very important 24 about what Dan said and why Harold might have picked 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 up on that.
1 And you can know that. That's information 2
that you can discover if you can if you will smell the 3
culture at that plant.
4 And I say that unreservedly. Those who go 5
to these sites and who come to these sites a lot, you 6
can smell it. You detect it very quickly.
7 So into 2014 they've got an unplanned 8
scrams. Just a number of issues that are identified 9
here.
10 MEMBER KIRCHNER: So not to be defensive 11 on the part of the utility, but what does it say about 12 the inspection process? I'm going back to slide 10.
13 So as a consequence of having this 14 incident obviously it attracted a lot of attention, 15 more thorough inspection and such, and now all of a 16 sudden you have 100 flood barriers that are 17 inadequate.
18 How long had they been inadequate?
19 MEMBER SKILLMAN: Great question.
20 MEMBER KIRCHNER: Right. But why didn't 21 the inspections pick this up sooner?
22 MEMBER SKILLMAN: I suspect it's because 23 they didn't do design basis inspections or other types 24 of inspections.
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71 MEMBER KIRCHNER: I'm just making an 1
observation. It's not just the applicant or the 2
utility but also raises questions about past 3
inspection practices.
4 MEMBER MARCH-LEUBA: One more question is 5
how many other plants have 100 flood barriers 6
inadequate.
7 MEMBER STETKAR: You raise that but again 8
we're talking about today post Fukushima. I suspect 9
that number is few because people have been looking at 10 flood barriers.
11 Now, the other thing that people aren't 12 looking at that we're going to catch the next time 13 something funny happens.
14 MEMBER MARCH-LEUBA: The munitions plant.
15 MEMBER STETKAR: Is we don't know the 16 answer to that because people haven't been looking for 17 that other thing.
18 MEMBER RICCARDELLA: Someone once said 19 prediction is difficult, especially of the future.
20 That sounds like Mark Twain.
21 MEMBER SKILLMAN: Slide 12. It was the 22 one item having to do with the EMRVs and solonoids 23 back in 2015.
24 Slide 13. Now we've gone from yellows to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 whites. And for 2015 there were two plants with 1
initiative events, cornerstones, two different at 2
Pilgrim and so on from the slide there.
3 Six plants with mitigating systems. Four 4
with emergency preparedness and one plant with 5
occupational radiation safety concerns.
6 Just looking at several of these at 7
Pilgrim in 2013 there was a white PI and initiating 8
events. And in two quarters in '13.
9 In 2015 at Pilgrim it was a white finding 10 in mitigating systems and a green finding in 11 mitigating systems. Next slide.
12 It was a white at Palisades. It was the 13 effective dose equivalent external dosimetry during an 14 outage that they had. There was one at Duane Arnold 15 regarding coatings that had to do with processes.
16 Next slide.
17 And two whites at Fort Calhoun. You see 18 at the bottom there 56 uncorrected greens at Fort 19 Calhoun. We've got a backup slide for that.
20 But when one pulls the thread one sees 21 that there is an awful lot of work at Fort Calhoun 22 that has needed attention for a long time. So it's 23 not surprising that Calhoun's been in the regulatory 24 position that they have been in.
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73 MEMBER RAY: Notice both of those cite 1
appendix B which is almost universal that when you 2
want to write a violation you cite appendix B but of 3
course you never inspect appendix B because that 4
annoys people.
5 But it's the standard citation basis is 6
appendix B, failure to comply with appendix B. But 7
the inspection that is the leading indicator kind of 8
thing you see very, very little or none inspections of 9
appendix B.
10 MR. WIDMAYER: I think it's also probably 11 accurate but Fort Calhoun was licensed prior to the 12 standard review plan becoming a standard for review of 13 the licensing of the plants.
14 So I think the standard review plan is 15 much more rigorous approach. Just cite that.
16 MEMBER SKILLMAN: And building on what 17 Harold said not just appendix B but criterion 3 design 18 control.
19 It is that combination that is so often 20 the debilitating event in the inspection.
21 MEMBER RAY: Well it's the easiest thing 22 to cite to, but actually I would say that organization 23 is problematic also although you rarely ever see a 24 citation to organization.
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74 MEMBER SKILLMAN: And it's overlooked.
1 You're right.
2 MEMBER RAY: But the independent review 3
which is part of organization, not criterion 3, I 4
don't think any plants comply with that anymore.
5 MEMBER SKILLMAN: Next slide, please.
6 Okay we're getting into oversight process for calendar 7
year '16.
8 The whites have been reduced to six 9
plants, five plants with mitigating cornerstone 10 issues. You can see them listed there. And one with 11 emergency response. Next slide.
12 The security cornerstone. I thought it 13 was appropriate we talk a little bit about security 14 and a little bit about fitness for duty because they 15 really are part of this culture that we are part of.
16 So the inspectable areas of the security 17 cornerstone are shown in this slide. Hard to read.
18 Let's go on to 19.
19 For calendar years '15 and '16 a finding 20 of greater than green means that finding could be 21 white, yellow, or red.
22 There were 12 plants in that category in 23 2015, 4 plants in that category in 2016.
24 So greater than green is not new, it just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 means that the finding isn't green, it's greater than 1
green. The details are SUNSI. They are reported to 2
Congress.
3 And we see that the greens have reduced 4
from 54 in calendar year '15 to zero in calendar year 5
'16.
6 VICE CHAIRMAN CORRADINI: I guess I don't 7
understand that last bullet. I don't understand the 8
last bullet at all.
9 MR. WIDMAYER: We're talking about green 10 findings now, not greater than green findings. Green 11 findings.
12 And they've been reduced from 54 in '15 to 13 zero in calendar year '16.
14 MEMBER SKILLMAN: You'll see it on the 15 slides. We've got the data for that.
16 MEMBER KIRCHNER: What's the takeaway.
17 What does that mean?
18 MEMBER SKILLMAN: The takeaway for me is 19 that the plants have really tightened up in their 20 security area. That tells me that the plants have 21 probably in the post 9/11 era have finally developed 22 a discipline that is --
23 MEMBER KIRCHNER: So if we went back and 24 looked at prior year data when the security 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 inspections were first implemented we would see just 1
a rapid decline to zero.
2 MEMBER SKILLMAN: If you look at slides 7 3
and 8 you will see that data.
4 CHAIRMAN BLEY: I've got to toss in my own 5
personal view on this.
6 MEMBER SKILLMAN: Sure.
7 CHAIRMAN BLEY: At the level we're going 8
through I don't really trust anything I learn. Where 9
I learn is going into individual events and 10 understanding exactly what happened and exactly what 11 the problem was and exactly what the proposed solution 12 is.
13 At this level I just don't have a hint of 14 that kind of information.
15 MR. WIDMAYER: And part of the challenge 16 is that we can have a secure meeting, we can have a 17 non-public meeting and discuss the security issues and 18 get a better answer.
19 CHAIRMAN BLEY: Not just security. All of 20 21 MEMBER SKILLMAN: -- vast majority of the 22 other events.
23 MR. WIDMAYER: Well, we picked the most 24 significant ones to discuss in some detail. Like I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 said if we got into trying to figure out what was 1
going on in green. I mean we could use the whole day 2
if you want.
3 MEMBER SKILLMAN: Maybe more than that.
4 Maybe Dennis's question begs an answer around how 5
often we discuss this as a committee. Because this is 6
the real data that is the heartbeat of the --
7 MEMBER STETKAR: Data is not the point is 8
what Dennis is trying to --
9 MEMBER SKILLMAN: Yes, I got that. The 10 details.
11 MEMBER STETKAR: Understanding why is ANO 12 in trouble and why have they continued to be in 13 trouble. What's really going on there. That's 14 important I think for this committee to understand.
15 Not numbers and spreadsheets.
16 MEMBER SKILLMAN: We can do that and the 17 way I would propose that we do that is to get into 18 that 95003 inspection that came out of the event and 19 discuss those details in a closed meeting.
20 CHAIRMAN BLEY: I think it would be useful 21 to have --
22 MEMBER POWERS: Dennis, I thought the 23 whole purpose of this was to identify those things 24 that we would like to plunge into the details. That 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 this was a grand overview by intent. That it was not 1
supposed to ferret out the details or explain the 2
details. It was simply to give us an overview to 3
identify things we want to know more about.
4 CHAIRMAN BLEY: That's a reasonable 5
interpretation. I don't think we discussed how it was 6
going to play out ahead of time.
7 For me it would be useful to find a few 8
and go into them.
9 MEMBER POWERS: But this is not the place 10 to do it.
11 MEMBER SKILLMAN: When we did this two 12 years ago or whatever it was we were at the 50,000 13 feet level which is where we are now. And if we want 14 something different we can do that.
15 CHAIRMAN BLEY: That's what I suggest.
16 We'll talk about that.
17 MEMBER SKILLMAN: But the template of this 18 meeting has been let's talk about the data and if we 19 want to dig more deeply into that data we can 20 certainly do that.
21 VICE CHAIRMAN CORRADINI: Not to belabor 22 the point, but at least in this area to the extent 23 that these things affect safety I care. If they don't 24 affect safety I don't think it's in our purview.
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79 MR. WIDMAYER: That's correct, yes. But 1
that's hard to say without digging into the details.
2 MEMBER MARCH-LEUBA: By definition the 3
effect of the quality frequency to be yellow and white 4
5 VICE CHAIRMAN CORRADINI: But that's why 6
I asked whether this was a qualitative or a 7
quantitative calculation. If it's a qualitative 8
calculation then I'm not so sure.
9 But my only point is I think we've had --
10 well I don't know, a handful of meetings over the last 11 12 years.
12 But the underlying theme is it has to 13 overlap and affect safety to the extent that we really 14 have -- that's where our expertise lies. At least 15 that's where my expertise I think lies.
16 MEMBER SKILLMAN: I'm the guy that said 17 hey Derek I think we ought to present security and 18 fitness for duty. And I believe from my 50 years the 19 next two topics are as safety intensive as any other 20 technical topic we deal with.
21 CHAIRMAN BLEY: Let's go ahead with them.
22 MEMBER SKILLMAN: So notice table 2 is 23 commercial nuclear power plants. Table 3 is fuel 24 plants.
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80 Table 2 is what's going on where the 1
cooling towers are. Table 3 is going on where the MUF 2
is.
3 And in 2015 205 inspections. You can see 4
the data. None of the findings were greater than 5
security level 4 which means that they were all low 6
level.
7 Greater than security level 4 is if you 8
will safety security.
9 And same with the fuel cycles. These do 10 not include force on force. There was one in 2015 11 that was greater than security level 4. I don't know 12 what the data is. But just to point out the numbers.
13 MEMBER BROWN: Dick, what's MUF again?
14 MEMBER SKILLMAN: Material unaccounted 15 for. That's u-235 that's not accounted for. Slide 16 21.
17 This is force on force. Twenty-two 18 inspections in 2015. Every force on force is a double 19 and so there should be 44 total regarding exercises 20 and the findings.
21 Notice that on 2015 there was just one 22 ineffective exercise. There were 26 inspection 23 findings. None were greater than level 4 in 2015.
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81 of what an ineffective or -- like the one above that, 1
uncertain exercises.
2 MEMBER SKILLMAN: What is an ineffective 3
exercise. And there's the definition. It's 4
ineffective implementation of its protective strategy.
5 MR. WIDMAYER: These are actually not 6
definitions. This is a description, a SUNSI 7
description of what the inspection finding actually 8
was that caused them to make this determination.
9 So there's a lot of different reasons 10 you'd have an ineffective -- no, this is the non-SUNSI 11 determination.
12 MEMBER SKILLMAN: This is from the NUREG 13 report that is released.
14 MR. WIDMAYER: Correct. So we're not 15 allowed to know where and when it happened but this is 16 what it is.
17 MEMBER BROWN:
Does inability or 18 ineffective, does that mean the bad guys got in?
19 CHAIRMAN BLEY: I don't think we can talk 20 about that.
21 MEMBER BROWN: Well, like where it is or 22 who it is or whatever, but I mean I guess I'm just 23 trying to get an understanding what an ineffective 24 exercise is.
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82 MEMBER SKILLMAN: Let's just leave it the 1
way it's written there. Again, I told Derek I think 2
it would be constructive for the members to know what 3
this information looks like. We can probably talk 4
about it offline sometime.
5 MEMBER DIMITRIJEVIC: I have a more basic 6
question. There is a table on page 7 also for 2015.
7 And I was wondering how this compares because here we 8
have 56 green findings and on page 20 says one of one 9
green findings in 2015. So why do we have --
10 MR. WIDMAYER: The chart is the number of 11 plants. The page 7 is the number of plants.
12 MEMBER DIMITRIJEVIC: Oh number of the 13 plants with the green findings. I see.
14 MR. WIDMAYER: And the details are the 15 actual, that's the number of findings. Doesn't tell 16 you which plant.
17 MEMBER DIMITRIJEVIC: I see. All right.
18 MEMBER SKILLMAN: Okay. Slide 23, please.
19 In 2016 there were 189 security 20 inspections that were conducted. These were on 21 commercial nuclear power plants, not force on force.
22 Fourteen on fuel plants.
23 There were six in 2016 that were greater 24 than security level 4. And the fuel plants none.
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83 Slide 24. Force on force. You can see 1
that there were 21 total force on force in '16, two 2
per, that would be 42 exercises. And there are the 3
data for those 42 exercises.
4 MEMBER DIMITRIJEVIC: I thought we had no 5
green findings in 2016 because we had the zero plants.
6 It's tough to follow some of this.
7 We say that when we went to zero plants on 8
page 8 and now we said we had 117 green findings in 9
2016.
10 MR. WIDMAYER: I can't really say but this 11 is just the number for the force on force. I can't 12 really say why --
13 MEMBER DIMITRIJEVIC: This was the number 14 without force on force. I'm looking on 22. So for 15 the commercial nuclear plants 2016 117 total number of 16 green findings.
17 MR. WIDMAYER: Yes, I can't --
18 MEMBER DIMITRIJEVIC: And when I go to 19 page 8 says number of the plants with green findings 20 zero.
21 MR. WIDMAYER: I can't explain that to 22 you.
23 MEMBER DIMITRIJEVIC: Okay.
24 MEMBER SKILLMAN: We are not attempting to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 reconcile all of the data. I was trying to make sure 1
that the committee understands what the heartbeat of 2
the oversight program is providing.
3 MEMBER DIMITRIJEVIC: Because we made the 4
statement that it was big improvement. That's only 5
why I'm sort of looking at this. We said there were 6
zero plants.
7 MEMBER POWERS: We will never get through 8
this if we continue to crosscheck. This is a 9
qualitative understanding of what has happened at the 10 plants.
11 MEMBER SKILLMAN: Let's keep on going.
12 Crosscutting issues. This is probably the most 13 important area for '15 and '16.
14 The crosscutting issues if you recall came 15 out of the Davis-Besse environment. And crosscutting 16 means that you have a number of if you will adverse 17 findings that give an indication if you will of site 18 culture.
19 At Duane Arnold it was consistent process.
20 This was initiated by the recognition of the failure 21 of the coatings in that containment. They failed to 22 control the application of the coating and the 23 coatings when failed could compromise the suction 24 strainers for emergency cooling which is why this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 became crosscutting for Duane Arnold.
1 Twenty-eight, Monticello. This had to do 2
with conservative bias. It had to do with the 3
calculations regarding flooding at the site.
4 MEMBER RICCARDELLA: Do you mean lack of 5
conservative bias?
6 MEMBER SKILLMAN: Correct.
7 MEMBER RICCARDELLA: Okay.
8 MEMBER SKILLMAN: Lack of conservative.
9 And if you read the documentation it wasn't just 10 there. Throughout the site there was this I don't 11 want to say cavalier, but there was not a conservative 12 bent toward decision-making.
13 Twenty-nine is Prairie Island 14 documentation. And this item was closed.
15 Thirty. And in 2016 there were no new 16 open issues identified for crosscutting.
17 Thirty-one. Okay, on the lefthand column 18 you see the safety cornerstones. There are seven that 19 Dan explained earlier.
20 And you can see the performance 21 indicators, the PIs that are related to the safety 22 cornerstones.
23 Slide 32. So for 2015 and '16 green is 24 all the performance and cornerstones objectives are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 met. White means they're outside of expected nominal 1
but related cornerstones objectives are met. And 2
yellow and red are showing reductions in safety 3
margin.
4 Thirty-three. There are eight plants with 5
white cornerstones in calendar year '15. At 6
Fitzpatrick this had to do with unplanned power 7
changes in 7,000 critical hours. Seven thousand is a 8
nominal operating year.
9 And if you do the arithmetic you find that 10 there were probably down powers or other power 11 affecting transients prior to the first quarter of 12 2015. Hence late 2013 into 2014 that would cause that 13 performance indicator to be high in the first quarter 14 of '15.
15 And then as the second quarter of '15 16 emerged the prior data fell off, causing the product 17 to be reduced and so on into the fourth quarter.
18 And the white threshold is greater than 19 six. So this is Fitzpatrick.
20 Next slide is Riverbend. Same type of 21 metric but it's unplanned scrams with complications.
22 Thirty-five, Salem 1 and Dresden. Same 23 kind of data. Notice Dresden seemed to have a more 24 difficult time having this performance indicator 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 decrease, meaning they were probably dealing with 1
something in mid to late 2014, in early 2015 that kept 2
that number from continuing to decrease.
3 MEMBER BROWN: Do you have fractions of 4
unplanned scrams? So we're dividing by --
5 MEMBER SKILLMAN: It's x/y.
6 MEMBER BROWN: So it's per hour. I guess 7
I don't understand the metrics.
8 CHAIRMAN BLEY: It's actually per year.
9 MEMBER POWERS: And there's a three-year 10 integration period.
11 MR. WIDMAYER: It's per four quarters.
12 Per the previous four quarters.
13 MEMBER SKILLMAN: It's a rolling average.
14 MEMBER BROWN: Okay. Now you can come up 15 with fractions.
16 CHAIRMAN BLEY: Mike, you weren't around 17 and Charlie in this business but back in the seventies 18 3.7 a year wasn't far off. Some people did a fair 19 amount more than that.
20 MEMBER POWERS: But unplanned scrams with 21 complications is a flag.
22 CHAIRMAN BLEY:
That's a
leading 23 indicator.
24 MEMBER POWERS: Well, I don't know how 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 leading it is. I think it's probably the product of 1
a lot of things. But it's certainly unusual to see 2
any complications nowadays.
3 MEMBER SKILLMAN: You hope you don't see 4
them, that is a scram with complications, but when you 5
have scram with complications it normally means one of 6
two things. You didn't implement your procedures 7
correctly or you have underlying hardware issues that 8
drove the plant in a direction that you do not want it 9
to go.
10 And both of those -- TMI was an unplanned 11 scram with complications. It just happened to end up 12 with core melt.
13 MEMBER BALLINGER: Nowadays you can go 14 years without having an unplanned scram.
15 MEMBER SKILLMAN: Most plants do.
16 MEMBER BALLINGER: So is it likely that 17 we're going to see -- since nobody experiences these 18 unplanned scrams that when we do get a scram there 19 might be complications because of --
20 MEMBER POWERS: There's no question that 21 an unplanned scram now has become a rare evolution.
22 It's just no question about it.
23 CHAIRMAN BLEY: You don't get the spurious 24 ones you used to get. So many of them happened 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 because something went wrong.
1 MEMBER SKILLMAN: In my own view part of 2
the performance improvement that we're seeing is very 3
much a function of the maintenance and owners taking 4
care of their equipment to make sure that you don't 5
have these spurious failures that trip the plant.
6 Slide 36. Oyster Creek, decrease. Notice 7
Sequoyah increasing 2015.
8 Thirty-seven. Indian Point increasing.
9 Prairie Island increasing.
10 Thirty-eight. This is 2016. No plants 11 with red or
- yellow, unplanned scrams with 12 complications Davis-Besse. It's holding steady. So 13 the trailing four quarters is not causing that number 14 to decrease. That number is staying the same so they 15 are still having problems.
16 MEMBER BALLINGER:
I have another 17 question. Can you break it down between merchant 18 plants and non-merchant plants?
19 MEMBER SKILLMAN: Not at this level you 20 can't. I mean we could dig into the data and probably 21 separate them.
22 MEMBER BALLINGER: I haven't seen anybody 23 do that but you could.
24 MEMBER SKILLMAN: You could.
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90 MEMBER REMPE: Get a grad student and give 1
them the report.
2 MEMBER BALLINGER: In general I think 3
merchant plants are up against it much more severely 4
with respect to financial issues and stuff like that.
5 So you don't know.
6 CHAIRMAN BLEY: There's been -- especially 7
through INPO there's been a really strong push to cut 8
down on scrams. So I think they're all feeling the 9
same.
10 MEMBER SKILLMAN: Thirty-nine. Indian 11 Point. One is Indian Point 3 is recovering. Prairie 12 Island 2 has recovered.
13 Forty. Sequoyah 1 has recovered. Salem 14 2 is still having difficulty in the trailing four 15 quarters for unplanned scrams.
16 Forty-one. Grand Gulf is struggling. And 17 Watts Bar 2 has been added to the database.
18 Forty-three. Now we kind of move over 19 into the plant assessment.
20 Forty-four. Dan presented this in his 21 opening comments and this is where maybe everybody 22 wants to take note.
23 Column one everything is dandy. Column 24 two a little bit of friction. Something is going on.
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91 Column three, a degraded cornerstone. Column four, 1
you're moving into 95003, there are real problems but 2
you haven't lost your keys. And column five is 0350 3
you've lost your keys.
4 And there is if you will as you go from 5
the bottom of this slide or bottom of the image there 6
to the top you can see the escalation of NRC response 7
and the identification of what the column means.
8 And you want to be in column one and you 9
want normal oversight. Normal oversight is you have 10 your residents, you have your scheduled inspections 11 and by and large there is a cadence that is healthy.
12 As you increase from column one to column 13 five you can see the increase in the investment by the 14 agency of inspection resources.
15 MEMBER BROWN: Can column one be a blank?
16 MEMBER SKILLMAN: No.
17 MEMBER BROWN: So having findings in green 18 means they found no problems.
19 MEMBER SKILLMAN:
Sure.
Uncited 20 violations.
21 MEMBER BROWN: Pardon?
22 MEMBER SKILLMAN: Uncited, not cited 23 violations is very common.
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92 yes, but that probably means you just weren't 1
inspected in that quarter.
2 MEMBER BROWN: I'm just -- not being a 3
civilian plant operator I was --
4 MR. WIDMAYER: You can have a lot of no 5
findings.
6 MEMBER BROWN: I'm just looking at the 7
previous graphs where we had 56 greens or whatever it 8
was, all these numbers of greens. Those are green 9
findings. That means there's no findings? Does that 10 mean they had findings but they were not worth talking 11 about?
12 MEMBER POWERS: A green finding simply 13 means that it goes to the corrective action program.
14 MEMBER SKILLMAN: I'll give you an 15 example. They might come in and do a review of your 16 calculations and they might find that the calculation 17 is absolutely pristine but the page numbers are not 18 accurate.
19 MEMBER BROWN: Not what?
20 MEMBER SKILLMAN: Not accurate. Page 1, 21 2, 3, 7, 8, 9 but the calculation is good and the 22 pages are all there but the page numbers are wrong.
23 And they might cite you uncited for documentation.
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93 me.
1 MEMBER SKILLMAN: No, I'm not kidding.
2 That's the type of thing that you might find in column 3
one. It would say something is wrong but fix it.
4 You'd say I'll put it in my corrective action program 5
and I'll fix it.
6 But it doesn't materially affect the 7
safety of the plant. There is that category of if you 8
will not cited violations are green.
9 MEMBER BROWN: I've never understood this 10 process.
11 MEMBER POWERS: Well, you're just not 12 trying. You'd understand it perfectly well if you 13 just tried.
14 MEMBER SKILLMAN: The inspectors provide 15 an absolutely essential valuable service. They will 16 come in and find things that the licensee is blind to.
17 And the inspectors will say we found this 18 but it really isn't related to safety but you better 19 fix it. And it's well done, okay.
20 But that's part of the culture at the site 21 to allow that to occur. And it's well done.
22 But sometimes they say you know what, 23 you've got this in two areas and that count might be 24 inaccurate because of what you did here.
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94 MEMBER BROWN: Okay. You're overwhelming 1
me with minutiae right now. I just roll my eyeballs.
2 And if I'd found the page numbers wrong I would have 3
taken a pen and marked them out and put a CB by them 4
and say I've corrected it and I'm done for this one.
5 Make sure the next one.
6 Now when they print it out it'll get the 7
right page numbers based on --
8 MEMBER SKILLMAN: And a resident inspector 9
might say you can simply do this but you better get it 10 fixed.
11 But the culture at the site will 12 communicate we'll put that in our corrective action 13 system. We'll take care of it. Uncited.
14 MEMBER BROWN: Okay.
15 MEMBER SKILLMAN: That's what level one 16 is, column one. Next slide.
17 Okay, 2015. How many plants are in which 18 column. And you might want to bounce from this slide 19 45 back to 44.
20 But in 2015 you can see who's in column 21 one, how many plants are in column one, two, three, 22 and four.
23 And I would observe that the takeaway here 24 is how many plants are in column four. That's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 serious. That's a lot of plants. That's 3 percent of 1
the plants in the country.
2 MEMBER BALLINGER: Are they the same 3
plants?
4 MEMBER SKILLMAN: Yes. You'll see. Forty-5 six, 2016, guess what. Three plants in column four.
6 CHAIRMAN BLEY: But nobody in column three.
7 MR. WIDMAYER: But did they go up or down.
8 That's what you want to know.
9 MEMBER POWERS: Well, what it does say is 10 the NRC is expending an awful lot of supplemental 11 inspection resources here.
12 MEMBER BROWN: So the threes are all 13 carryovers from the previous zero quarter, is that 14 right? Because there were no degraded cornerstones in 15 column three during quarter 1, 2, 3 and 4.
16 MEMBER SKILLMAN: Basically, yes.
17 MEMBER BROWN: I'm just making sure I 18 understand.
19 MEMBER SKILLMAN: You're right. And once 20 you get over into column four you've got some work to 21 do. It might take you a year to get out of that.
22 MR. WIDMAYER: Or more.
23 MEMBER SKILLMAN: Or more. It might take 24 you two years. That's why I said when you're in 95003 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 you've got to start printing money. It's expensive to 1
get out. I mean you've got to do a lot to regain the 2
NRC's trust.
3 MEMBER REMPE: When you say you spent a 4
lot of money it's not just the consultants you hire.
5 The agency charges them.
6 MEMBER SKILLMAN: Plus you have to do real 7
work at the site. When you get into that situation 8
for the people who are just not really putting in a 9
day's work now they are whether it's correcting 10
- hardware, correcting documentation, correcting 11 calculations, modifying the plant.
12 When you get into column three you really 13 begin to see people getting work done.
14 CHAIRMAN BLEY: Dick, your time is about 15 up and you've got about eight more slides.
16 MEMBER SKILLMAN: Two minutes. Okay, 47.
17 There are your column four plants.
18 Forty-eight.
One deviation.
Dan 19 mentioned when you might be in multiple degraded 20 cornerstones there might be a deviation to allow you 21 to back out without going through extraordinary effort 22 and this is one case where that plant was removed from 23 four to column two.
24 They scheduled another IP95002 inspection 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 which is a very thorough inspection.
1 Very quickly, 49. Fitness for duty.
2 Going to go through these quickly. There are the --
3 those are the types of facilities that are being 4
inspected or that are if you will subject to 10 CFR 26 5
fitness for duty rule.
6 Fifty. Get an idea of the tests, pre-7 access, random, for cause, post event, and follow-up.
8 We probably know those from our experience here or 9
other places.
10 Fifty-one, subversion is where people are 11 trying to smoke the system, get by with if you will 12 abuse without being detected.
13 The last bullet, the construction sites 14 have higher positive rates in pre-access. These are 15 people coming in to work and they get discovered.
16 MEMBER BALLINGER: The number of Harley-17 Davidson riders.
18 MEMBER SKILLMAN: Not necessarily. And I 19 know that that is a commonly held point of view but 20 there are supervisors and folks like us who get caught 21 in pre-access. So it isn't just people with tattoos 22 and Harleys.
23 Fifty-two. The overall data for the 24 industry, the overall positive is about a little over 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 half a percent. It's low, but it's higher than it's 1
been in the last couple of years.
2 Total tests in calendar year '14 increased 3
because of the construction sites. About 64 percent 4
of the positives are at pre-access. Those are people 5
knocking on the door to come to work.
6 And the random testing identified about 20 7
percent of the substance abusers. That's people like 8
us getting called out to be checked.
9 MEMBER BALLINGER: So what that last one 10 means, are you saying that random testing identified 11 19.5 percent. Does that mean it only caught 19.5 12 percent and there are a lot more?
13 MEMBER POWERS: No, it's of those caught.
14 MEMBER SKILLMAN: One in five on random 15 was positive.
16 CHAIRMAN BLEY: But others were caught 17 because they were falling down and we took you out of 18 there.
19 MR. WIDMAYER: There are five types of 20 tests. The random test catches 20 percent of the 21 positives. The pre-access, the one before you get 22 your job catches most. That's 64 percent.
23 MEMBER BALLINGER:
So this is a
24 significant winnowing down.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 MR. WIDMAYER: Right. But nonetheless 1
these are the people that got the job and have an 2
issue after they're at work.
3 MEMBER SKILLMAN: Let's go on. We're 4
almost done. I want to give Dennis the floor back.
5 Fifty-four. For cause. The highest rate 6
of 12 percent. And notice that three substances are 7
about 80 percent, marijuana, alcohol and amphetamines 8
and cocaine is fourth.
9 MEMBER BALLINGER: So cocaine would also 10 include opioids in general?
11 MEMBER SKILLMAN: That's the next group.
12 Fifty-four, please. When there is a violation you've 13 got a 24-hour report. Ron, this is the bullet I 14 wanted to point to relative to the Harley riders.
15 Almost all the Harley riders are supervisors.
16 Forty-five of the 25-hour reports of those 17 over half were supervisors and nine are licensed 18 operators.
19 And maybe that's where we can stop here.
20 This is why I wanted to bring the fitness for duty 21 information into this meeting because we do have an 22 epidemic in the country and our industry is not immune 23 from that epidemic.
24 I just thought this was information that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 we should know about.
1 CHAIRMAN BLEY: Just to note to everyone 2
out of that 60 percent that are caught pre job or 3
whatever you call that we contributed one, no names.
4 And it's because of a confusion.
5 One of our consultants got a note saying 6
report for drug testing and the consultant said no 7
because I'm not in town. But he's no. And within 24 8
hours you have to report a no. And we lost him. Very 9
unhappy.
10 So don't ever say no. Say let's arrange 11 for a time for me to come and get it. Because if you 12 say no you're in that group. You failed. Just don't 13 ever say no to a drug test here unless you want to 14 leave.
15 You're done?
16 MEMBER SKILLMAN: One more slide and we're 17 done.
18 Industry trends. No long-term industry 19 trends. And the IMC-0313 will now replace the 20 industry trends program with the ROP PIs. So it's a 21 change in how industry trends will be addressed by the 22 agency in the future.
23 MEMBER BALLINGER: I'm assuming that the 24 NRC has dealt with this but I don't know whether we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 have the combination of a state where marijuana is 1
legal and a state in which there's a power plant. I 2
don't know the answer to that.
3 CHAIRMAN BLEY: It's illegal federally so 4
it's illegal for anybody under our program. That's 5
clear.
6 MEMBER BROWN: That doesn't mean you can't 7
get nailed. If you go to a concert, one of these big 8
concerts, just don't breathe because literally if you 9
get nailed the next day you're very likely to be 10 tested.
11 MEMBER SKILLMAN: Dennis, I'm done.
12 CHAIRMAN BLEY: Okay, thanks Dick.
13 MEMBER SKILLMAN: I want to thank the NRC 14 staff. Thank you.
15 CHAIRMAN BLEY: Thanks to the NRC staff.
16 Thanks to you and Derek. I think the subcommittee, 17 we're going to have a little executive session and 18 then we ought to do this more often and we ought to 19 talk about how we like to focus it.
20 We are recessed until 10 till. See you 21 then.
22 (Whereupon, the above-entitled matter went 23 off the record at 10:36 a.m.)
24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 Recent Changes to the Reactor Oversight Process Dan Merzke - NRR/DIRS/IRAB Jim Isom - NRR/DIRS/IRIB U.S. Nuclear Regulatory Commission December 7, 2017
Scope 2
- Repetitive Degraded Cornerstone
- Substantive Cross-Cutting Issue (SCCI)
Process
- Action Matrix criteria
- Inspection Finding Resolution Management (IFRM)
- Engineering Inspections
Repetitive Degraded Cornerstone 3
- Definition changed in 2015 from a cornerstone that is degraded (1 Yellow input into the Action Matrix or 2 White inputs in same cornerstone) for more than four consecutive quarters to one degraded for more than five consecutive quarters.
- Change requested by Regions because challenged in completing IP 95002 supplemental inspections within four quarters.
- No licensee has met the criteria (original or revised) since Pilgrim 2014.
Substantive Cross-Cutting Issues
- Implemented in 2006 as part of the Davis Besse Lessons Learned.
- Purpose of an SCCI is to inform the licensee that the NRC has a concern with the licensees performance in the cross-cutting area and to encourage the licensee to take appropriate actions before more significant performance issues emerge.
- Cross-Cutting Areas:
- Human Performance
- Problem Identification and Resolution (PI&R)
- Safety Conscious Work Environment (SCWE) 4
Substantive Cross-Cutting Issues
- Increased threshold for cross-cutting theme from 4 to 6 findings with same aspect in 12 month assessment period
- Created backstop at cross-cutting area level (HU=20; PI&R=12 during 12-month assessment period)
- Eliminated term substantive
- Eliminated questions for opening a Cross-Cutting Issue (CCI).
- First time = theme documented in assessment letter
- Second consecutive = theme documented in assessment letter
- Third consecutive = Cross-Cutting Issue
- Develop standard closure criteria (inspection) 5
Impact of CCI Changes
- No licensee has been issued a CCI
- 2 licensees have tripped revised criterion for a cross-cutting theme with 6 findings with same CCA (Ft Calhoun, Pilgrim)
- 6 licensees have received 5 findings with the same CCA
- 4 licensees have tripped the cross-cutting theme at the cross-cutting area level (Clinton, Ft Calhoun, Pilgrim, River Bend)
- Licensees with cross-cutting themes are generally plants with performance issues 6
Impact of CCI Changes
- Numbers of licensees meeting the old criterion for a cross-cutting theme with 4 CCAs is consistent with licensee performance prior to revision (6-7 per assessment period)
- Those licensees tripping the old criterion are not repeating in subsequent periods, indicating they either do not have a performance issue in the cross-cutting aspect, or the licensees are taking corrective actions to address issues before tripping the criterion for a theme.
7
Degraded Cornerstone Original
- 1 Yellow input into the Action Matrix
- 2 White inputs in the same cornerstone Revised (01/01/16)
- 1 Yellow input
- 3 White inputs in the same cornerstone 8
Basis
- No documented technical basis for criterion of two White inputs in the same cornerstone indicative of a degraded cornerstone (moderate degradation in safety performance), or two White inputs are equivalent to one Yellow input.
- Probabilistic Risk Assessment concluded at least 3 White inputs needed to cross the White/Yellow threshold.
9
Impact
- No licensee has met the original or revised definition of Degraded Cornerstone since implementation in 2016.
10
Timely Resolution of Inspection Findings
- Inspection Finding Resolution Management (IFRM)
- Goal: Improve the efficiency, effectiveness, and timeliness of the inspection and SDP processes.
- Inspection Finding Review Board (IFRB) aligns stakeholders early in the process on both the performance deficiency and the path forward for assessing the significance of the finding.
- Includes enhanced metrics and performance monitoring.
- A trial period for IFRM began November 2016 and is expected to extend through 2017.
- IFRM effectiveness review planned for early CY2018.
11
Engineering Inspections
- Introduction/Background
- How Did We Get Here?
- Pilot Component Design Bases Inspections and Equipment Qualification Inspections Conducted During CY 2015 and CY 2016 12
Design Bases Assurance (DBA) and EQ Inspections
- NRC Started Performing New Design Bases Assurance Inspection - IP 71111.21M and EQ Inspection - IP 71111.21N in CY 2017 13
Engineering Effectiveness and Efficiency Review
- Make recommendations on improving both the effectiveness and efficiency of the suite of engineering inspections within the ROP
oversight/rop-design-insp-review.html 14
Engineering Effectiveness and Efficiency Review - Scope IP 71111.05T, Fire Protection (Triennial) or IP 71111.05XT, Fire Protection-NFPA 805 (Triennial)
IP 71111.07, Heat Sink Performance IP 71111.08, Inservice Inspection Activities IP 71111.17T, Evaluations of Changes, Tests, and Experiments IP 71111.21M, Design Bases Assurance Inspection (Team)
IP 71111.21N, Design Bases Assurance Inspection (Program) 15
Engineering Effectiveness and Efficiency Review
- Public Meetings Conducted/Planned (June 6th; Oct 11th; Dec 12th; Jan 17th and 18th)
- Comments Received from Industry and Members of the Public
- Use of Licensee Self-Assessments
- Engineering Program Inspections Options 16
Path Forward
- Discuss NRC Proposed Options with Public Stakeholders during Jan 17 - 18, 2018 Meeting
- Commission Paper - Summer of 2018
- Approved Changes to be Implemented in CY 2020 or sooner 17
Questions/Comments 18
ACRS 647th Full Committee Meeting Summary of Operating Experience for CY2015 and 2016 Gordon Skillman, ACRS December 7, 2017 1
2 ROP Framework
3 ROP Process
4 CY2015 and 16 ROP Total Number of Plants in ROP Evaluation:
Region I = 25 Region II = 34 Region III = 23 Region IV = 19 TOTAL = 101
5 CY2015 and 16 ROP Inspection Findings - Quantitative Thresholds Red CDF greater than 10-4CDF or LERF greater than 10-5 LERF Yellow CDF greater than 10-5 and less than or equal to 10-4 CDF or LERF greater than 10-6 and less than or equal to 10-5 LERF White CDF greater than 10-6 and less than or equal to 10-5 CDF or LERF greater than 10-7 and less than or equal to 10-6 LERF Green CDF less than or equal to 10-6 CDF or LERF less than or equal to 10-7 LERF
6 CY2015 and 16 ROP Inspection Findings (Qualitative Definitions)
Green: a finding of very low safety or security significance
Greater-Than-Green: a finding of more than very low significance - security cornerstone only
White:
a finding of low to moderate safety or security significance
Yellow: a finding of substantial safety or security significance
Red: a finding of high safety or security significance
7 CY2015 ROP CY 2015 Inspection Findings
? = Red, Yellow, or White designation of GTG is SUNSI Number of Plants Insp.
Find.
Safety Cornerstone Initiating Events Mitigating Systems Barrier Integrity Emerg.
Prep.
Occ. Rad Safety Pub. Rad.
Safety Security Red 0
0 0
0 0
0
?
Yellow 2
3 0
0 0
0
?
White 2
6 0
4 1
0
?
GTG 12 Green 55 85 41 23 34 14 56
8 CY2016 ROP CY 2016 Inspection Findings
? = Red, Yellow, or White designation of GTG is SUNSI Number of Plants Insp.
Find.
Safety Cornerstone Initiating Events Mitigating Systems Barrier Integrity Emerg.
Prep.
Occ. Rad Safety Pub. Rad.
Safety Security Red 0
0 0
0 0
0
?
Yellow 2
2 0
0 0
0
?
White 0
3 0
1 0
0
?
GTG 4
Green 54 91 42 16 31 10 0
9 CY2015 & 16 ROP Inspection Findings
Five Yellows (Five in 2015, Four in 2016)
- Two Each at Arkansas 1 and 2 (Both CY2015 and 2016):
- Initiating Events Cornerstone
- Mitigating Systems Cornerstone
- One at Oyster Creek (CY2015):
- Mitigating Systems Cornerstone
10 CY2015 & 16 ROP Inspection Findings
Four Yellows - Arkansas Nuclear 1 and 2 - Historic:
- Initiating Events Cornerstone:
Failure to Follow the Materials Handling Program during the Unit 1 Generator Stator Drop - Initially in 1st QTR 2014 LOOP of 6 days Unit 1; Partial LOOP Unit 2
- Mitigating Systems Cornerstone:
Inadequate Flood Protection for Auxiliary and Emergency Diesel Fuel Storage Buildings Concurrent with Stator Drop Event Over 100 Flood Barriers Inadequate
- Placed in Col 4 of Matrix Assessment
- Supplemental Inspection Procedure (IP) 95003 planned
11 CY2015 & 16 ROP Inspection Findings
Four Yellows - Arkansas Nuclear 1 and 2 - Recent:
2nd & 3rd QTRs 2014 - Unplanned Scrams/7000 Hrs White PI
Subsequent decision to also conduct Supplemental Inspections 95001 and 95002
3 Supplemental Inspections Conducted Jan & Feb 2016
Entergy submitted ANO Comprehensive Recovery Plan Area Action Plans, May 2016 to respond to recover from Col 4
NRC Issued Confirmatory Action Letter (CAL) June 2016
Most Recent Inspection July 2017 indicates only 2 Action Plans require further inspection (still several individual actions needing closure)
12 CY2015 & 16 ROP Inspection Findings
One Yellow - Oyster Creek:
- Mitigating Systems Cornerstone:
Inadequate measures for the suitability of applications of materials and processes (maintenance) for the EMRV solenoid-operated actuators.
10 CFR Part 50, Appendix B, Criterion III, Design Control Technical Specification 3.4.B, Automatic Depressurization System, CDF = Mid E-5 Also met criteria for Old Design Issue - not aggregated into Matrix Assessment No change in Matrix Response Column Supplemental Inspection completed Nov 2015 Corrective Actions Completed redesigned EMRV actuators installed
13 CY2015 ROP Inspection Findings
Whites - 13 Plants
- 2 Plants in Initiating Events Cornerstone:
2 Different at Pilgrim
- 6 Plants in Mitigating Systems Cornerstone:
Various Systems / Causes
- 4 Plants in Emergency Preparedness Cornerstone:
3 for inaccurate Emergency Action Levels (EALs)
- 1 Plant in Occupational Radiation Safety Cornerstone:
Unusual - Palisades
14 CY2015 ROP Inspection Findings
2 Whites at Pilgrim
Historic
- 3Q2013 - White PI in Initiation Events Cornerstone:
Unplanned scrams w complications > 1
- 4Q2013 - White PI in Initiation Events Cornerstone:
Unplanned scrams w complications > 1 Unplanned scrams per 7000 Hrs > 3
- Two Parallel White PIs equals White Inspection Finding CY2015
- 1Q2015 - White Finding in Mitigating Systems Cornerstone:
Failure to Identify, Evaluate & Correct A SRV Failure to Open in Manual Actuation.
For One Year - 2 of 4 SRVs in Degraded Condition
- 1Q2015 - Green Finding in Mitigating Systems Cornerstone:
Inadequate Operability Assessment of C SRV
15 CY2015 ROP Inspection Findings
1 White at Palisades
- Unusual White Finding in Occupational Radiation Cornerstone:
Failure to Monitor the Highest Exposed Part of the Compartment When Using Effective Dose Equivalent External (EDEX) during replacement of Control Rod Drive Housings 10 CFR 20.1201, Occupational Dose Limits for Adults Technical Specification 5.4 Procedures
1 White at Duane Arnold
- Interesting White Finding in Mitigating Systems Cornerstone:
Inadequate quality controls during the application of torus coating resulted in unqualified torus coating in excess of emergency core cooling system (ECCS) suction strainer design debris loading margin (BWR Precursor to GSI-191) 10 CFR Part 50, Appendix B, Criterion IX, Control of Special Processes
16 CY2015 ROP Inspection Findings
2 Whites at Fort Calhoun
Historic
- White Finding in Mitigating Systems Cornerstone - 4th QTR 2014 Failure to Correctly Translate Design Requirements into Installed Plant Configuration 10 CFR Part 50, Appendix B, Criterion III, Design Control CY2015
- White Finding in Mitigating Systems Cornerstone - 1st QTR 2015 Failure to Ensure Tornado Missile Protection for Site Components 10 CFR Part 50, Appendix B, Criterion III, Design Control
- 56 Uncorrected Greens at Ft Calhoun in Mitigating Systems cornerstone during same 2 QTRs
17 CY2016 ROP Inspection Findings
Whites - Reduced to 6 Plants
- 5 Plants in Mitigating Systems Cornerstone:
- Dresden 2
- Pilgrim
- River Bend 1
- Oyster Creek
- Hope Creek 1
- 1 Plant in Emergency Response Cornerstone:
- Ginna
18 CY2015 & 16 ROP Security Cornerstone
19 CY2015 & 16 ROP Inspection Findings - Security Cornerstone
Plants Greater-Than-Green; 12 in 15, 4 in 16
GTG is not a new category, it means the finding was either white, yellow, or red
Details are SUNSI and not publically available
But NUREG-1885 - Annual non-SUNSI report provided to Congress
Greens Reduced from 54 in CY 2015 to 0 in CY 2016
20 CY2015 ROP Security Cornerstone Baseline Inspection Findings
21 CY2015 ROP Security Cornerstone - Inspection Findings Force - on - Force Exercises
22 CY2015 ROP Force-On-Force Exercises
- 1 Ineffective Exercise:
licensees inability to demonstrate an effective implementation of its protective strategy to defend designated target set components
- 4 Indeterminate Exercises:
site responders neutralized adversaries using practices unanticipated by the design of the protective strategy site responders demonstration of use-of-force was inconsistent with the licensees protective strategy exercise controllers failed to control drill artificialities anomalies with the control of the exercise and performance related to the sites protective strategy implementation
23 CY2016 ROP Security Cornerstone Baseline Inspection Findings
24 CY2016 ROP Security Cornerstone - Inspection Findings Force - on - Force Exercises
25 CY2016 ROP Force-On-Force Exercises
- 1 Ineffective Exercise:
licensees inability to demonstrate an effective implementation of its protective strategy to defend designated target set components
- 1 Marginal Exercise:
adversary(ies) was neutralized at a location, or making preparations to enter a location, that contained a single element target set
- 1 Indeterminate Exercises:
licensee failed to properly control the exercise, which resulted in the NRC inspection teams inability to assess the licensees capability to implement its protective strategy 2 Exercises Cancelled due to weather
26 Cross-Cutting Issues - 2015
All Under Human Performance
Duane Arnold
SCCI H.13 - Consistent Process
Monticello
SCCI H.14 - Conservative Bias
Prairie Island 1 and 2
SCCI H.7 - Documentation CY2015 & 16 ROP
27 Open Cross-Cutting Issue - 2015
Duane Arnold - SCCI H.13 - Consistent Process
Identified as a concern (not finding) in Mid-Year 2012 Assessment - CAs implemented
2013 observed progress, but NRC remained concerned
Four 2014 inspection findings with this CCI
Therefore Opened in 1st QTR 2015
Root Cause completed and CAs implemented
Closed in Annual Assessment Report for 2015
Two separate problem identification and resolution inspection samples completed with no new H.13 findings CY2015 & 16 ROP
28 Cross-Cutting Issues Closed - 2015
Monticello - SCCI H.14 - Conservative Bias
Adverse trend in this CCI identified in Oct 2013
Five inspection findings with this CCI in four straight quarters
CCI identified at Mid-Year 2014
Delays in responding with cause evaluation
Closed in Mid-Cycle Assessment Report for 2015
Only one H.14 finding since 3rd QTR 2014 = Sustained Improvement CY2015 & 16 ROP
29 Cross-Cutting Issues Closed - 2015
Prairie Island - SCCI H.7 - Documentation
Four inspection findings with this CCI in four straight quarters
CCI identified at Mid-Year 2014
Second year annual assessment has this SCCI concern
Closed in Mid-Cycle Assessment Report for 2015
Corrective Actions completed and No H.7 findings for 4 consecutive QTRs CY2015 & 16 ROP
30 Cross-Cutting Issues - 2016
No New Open Issues in 2016 !
CY2015 & 16 ROP
31 CY2015 and 16 ROP
32 CY2015 and 16 ROP Performance Indicators
Green: performance within an expected level where all cornerstone objectives are met
White: performance outside an expected range of nominal utility performance but related cornerstone objectives are met
Yellow: related cornerstone objectives are met, but with a minimal reduction in safety margin
Red: significant reduction in safety margin in area measured by the PI
33 CY2015 ROP Performance Indicators NO Plants with Red or Yellow Eight Plants with White IE03 - Unplanned Power Changes / 7000 Critical Hrs Fitzpatrick (Multiple downpowers due to Main Condenser tube leakage for several quarters beginning 4Q12. Retubing completed during refuel outage: Oct 2014 - PI improved to Green by 3Q15.)
White Threshold > 6.0 1Q 2Q 3Q 4Q 16.4 7.3 4.1 0.8
34 CY2015 ROP Performance Indicators IE04 - Unplanned Scrams with Complications River Bend 1 White Threshold > 1.0 1Q 2Q 3Q 4Q 2.0 2.0 2.0 0
35 CY2015 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Salem 1 Dresden 2 White Threshold > 3.0 1Q 2Q 3Q 4Q 3.7 0.9 0.9 0
White Threshold > 3.0 1Q 2Q 3Q 4Q 3.4 1.6 1.6 1.7
36 CY2015 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Oyster Creek Sequoyah 1 (3 scrams 3Q and 1 more in 4Q)
White Threshold > 3.0 1Q 2Q 3Q 4Q 2.7 3.6 2.5 1.6 White Threshold > 3.0 1Q 2Q 3Q 4Q 0.8 0.9 3.7 4.8
37 CY2015 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Indian Point 3 Prairie Island 2 White Threshold > 3.0 1Q 2Q 3Q 4Q 0.9 2.7 2.8 3.7 White Threshold > 3.0 1Q 2Q 3Q 4Q 0
1.7 1.7 3.2
38 CY2016 ROP Performance Indicators NO Plants with Red or Yellow Six Plants with White IE04 - Unplanned Scrams with Complications Davis-Besse White Threshold > 1.0 1Q 2Q 3Q 4Q 2.0 1.0 2.0 2.0
39 CY2016 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Indian Point 3 Prairie Island 2 (3 scrams in CY2015: April, June, December )
White Threshold > 3.0 1Q 2Q 3Q 4Q 3.7 3.5 1.7 0.8 White Threshold > 3.0 1Q 2Q 3Q 4Q 3.6 1.2 1.2 0
40 CY2016 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Seqouyah 1 Salem 2 White Threshold > 3.0 1Q 2Q 3Q 4Q 4.4 3.9 0.9 0
White Threshold > 3.0 1Q 2Q 3Q 4Q 2.7 3.6 3.7 3.3
41 CY2016 ROP Performance Indicators IE01 - Unplanned Scrams per 7000 Critical Hours Grand Gulf 1 Watts Bar 2 began tracking PIs in 3Q2015 with No Data In 1QCY2016 - 1 PI with Data - EP02 (ER Drill Participation) was Green Starting 4QCY2016 - about 1/2 of PIs with Data - all Green White Threshold > 3.0 1Q 2Q 3Q 4Q 0.9 2.7 3.1 4.6
42 CY2015 and 16 ROP ROP Action Matrix Inspection Findings
+
Performance Indicators
=
Plant Assessment
43 ROP Action Matrix Assessment
Column 5: Unacceptable Performance
Column 4: Multiple/Repetitive Degraded Cornerstone
Column 3 Degraded Cornerstone
Column 2: Regulatory Response
Column 1: Licensee Response CY2015 and 16 ROP
44 CY2015 and 16 ROP
45 CY2015 ROP ROP Action Matrix Assessment Number of Plants in Each Column (per QTR)
Col 1 Col 2 Col 3 Col 4 Col 5 QTR Licensee
Response
Regulatory
Response
Degraded Cornerstone Multiple/Repetitive Degraded Cornerstone Unacceptable 1
78 19 1
2 0
2 83 14 0
3 0
3 92 5
0 3
0 4
91 6
0 3
0
46 CY2016 ROP ROP Action Matrix Assessment Number of Plants in Each Column (per QTR)
Col 1 Col 2 Col 3 Col 4 Col 5 QTR Licensee
Response
Regulatory
Response
Degraded Cornerstone Multiple/Repetitive Degraded Cornerstone Unacceptable 1
89 8
0 3
0 2
87 10 0
3 0
3 91 6
0 3
0 4
91 6
0 3
0
47 CY2015 & 16 ROP Action Matrix Summary Lowlights Pilgrim 1 - 6 consecutive QTRs in Col. 3 followed by 7 consecutive QTRs in Col. 4 (starting 4th QTR 2013)
Arkansas Nuclear 1 & 2 - 9 consecutive QTRs in Col. 4 (starting 4th QTR 2014)
Davis-Besse - 5 consecutive QTRs in Col. 2 (starting 4th QTR 2015)
River Bend 1 - 8 consecutive QTRs in Col. 2 (3rd QTR 2014 to 3rd QTR 2016)
Millstone 3 - 5 consecutive QTRs in Col. 2 (3rd QTR 2014 to 4th QTR 2015)
48 CY2015 & 16 ROP Action Matrix - One Deviation
- Monticello - Feb 2015 Entered Col 3 (Degraded Cornerstone) 2nd QTR 2013 Yellow in Mitigating Systems Cornerstone IP95002 Supplemental Inspection Completed Dec 2014 - Closed Yellow Greater-Than-Green in Security Cornerstone 4th QTR 2014 Definition of Repetitive Degraded Cornerstone Met - Move to Col 4
- Due to successful completion of IP95002 inspection and of biennial PI & R inspection;
- EDO Approved ROP Action Matrix Deviation, assigned to Col 2
- Another IP95002 Inspection Scheduled
49 CY2015 & 16 FFD Fitness for Duty
- 61 operating reactor sites
- 2 reactor construction sites (Summer, Vogtle)
- 4 formerly operating reactor sites (Crystal River, Kewaunee, San Onofre, Zion)
- 5 corporate program offices
- 1 contractor/vendor organization (INPO)
- Tests conducted on licensee and C/V employees
- 5 Types of Tests Conducted:
- Pre-Access (applicants for employment)
- Random (unscheduled/unannounced for employees)
- For Cause (behavior of, or information received about employee)
- Post-Event (after an event involving human error)
- Follow-up (after a positive test)
51 Most Recent FFD Fitness for Duty Data*
- Three Multi-year Trends being Tracked:
- Subversion attempts prevalent since CY2011 (18 to 21% of violations: 143 to 187 events per year) with 54 to 66% of sites reporting at least one.
- Amphetamine positive results increasing since CY2008 (from 3.8%
(in 2008) to 10.6% (in 2014) of drug & alcohol positives.
- Reactor construction sites have higher positive rates, primarily in pre-access and random tests, and have higher incidence of subversion attempts than operating reactor sites.
- 2014 Data; Newer Data not compiled.
52 Most Recent FFD Fitness for Duty Data (cont.)
Overall industry positive rate = 0.68%
Low, but higher than CY12 and 13 (both were 0.62%)
Total tests in CY2014 increased by 3%
Due mainly to increase in construction site tests
7% of facilities use stricter cutoff levels than required Approx 64% of positives and refusals occur at pre-access
Prevents access, directly protecting public health and safety
Random testing identified 19.5% of substance users
Identifies more employees using substances than pre-access
53 Most Recent FFD Fitness for Duty Data (cont.)
For cause testing had highest positive rate (12%)
(11.88% in CY12; 13.40% in CY13)
Three substances accounted for 88% of positives
Marijuana (53.2%), Alcohol (24.1%), Amphetamines (10.6%)
Cocaine knocked out of 3rd place: was 2nd most from 1990 to 2008 and 3rd most from 2009 to 2013. Cocaine is 4th with 10%
12% (9) of facilities test for other substances: barbiturates, benzodiazepines, hydrocodone, hydromorphone, methadone, oxycodone, oxymorphone, propoxyphene, suboxone
54 Most Recent FFD Fitness for Duty Data (cont.)
Events concerning individual employee violations must be reported to NRC within 24-hours Forty-five 24-hour reportable events
28 involved Supervisors (increase in random positives poses potential problem)
9 involved NRC-Licensed Operators Events concerning lab performance/method, quality control, or specimen collection must be reported to NRC within 30-hours Five 30-day reports
67% decrease from previous year
55 CY2015 ITP Industry Trends Program 2015 Long Term Industry Trends
No statistically significant adverse trends 2015 Short Term Industry Trends
No statistically significant adverse trends
56 Questions ?