ML18204A022
| ML18204A022 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 10/01/2018 |
| From: | Joseph Holonich NRC/NRR/DLP/PLPB |
| To: | Dennis Morey NRC/NRR/DLP/PLPB |
| Holonich J | |
| Shared Package | |
| ML18197A192 | List: |
| References | |
| Download: ML18204A022 (4) | |
Text
October 1, 2018 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM: Joseph J. Holonich, Senior Project Manager /RA/
Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF AUGUST 30, 2018, MEETING TO DISCUSS THE NUCLEAR ENERGY INSTITUE INTRODUCTION OF ENTRY CRITERIA FOR OPERABILITY DETERMINATIONS On August 30, 2018, U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 meeting with representatives from the Nuclear Energy Institute (NEI) and industry. These organizations will be referred to collectively as the industry in this summary. The purpose of the meeting was for the industry to introduce their proposed entry criteria for operability determinations. All information related to the meeting and discussed in this summary can be found in the Agencywide Documents Access and Management System Accession No. ML18197A192.
At the meeting, industry gave a presentation that described the entry criteria for the operability-determination process contained in the draft NEI 18-03, Operability Determination.
Also, the presentation included examples of how the criteria would be applied. Following the presentation, the NRC staff noted that it understood the concerns outlined in the presentation and that it would look to provide its perspective at the next meeting to be held in approximately 30 days. An action from the meeting was for the NRC staff to evaluate the information from this meeting in about two weeks and then identify some dates for the next meeting.
The NRC staff asked a number of questions to help it better understand the process. One question the NRC asked was why 10% was selected as a criterion. Industry explained that 10%
was selected based on acknowledging that structures, systems, and components are designed, licensed, and installed with substantial margins. If the installed margin is amenable to an estimate, and the margin loss is estimated to be approximately 10% or less, then the operability-determination process would not be entered. It was viewed as a starting point for now and may be adjusted as development of guidance moves forward.
CONTACT: Joseph J. Holonich, NRR/DLP 301-415-7297
D. Morey Another question asked was about a number of elements contained in Inspection Manual Chapter (IMC) 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety, not covered by the operability-determination process currently being developed by industry. Industry responded that it had limited the focus of the process based on the technical specification definition of operability. As interaction with the NRC continues, industry will consider if they wish to include additional elements.
One question requested information on how issues that do not fall into the formal process currently being developed, would be handled. Industry noted that the operability-determination process focuses on the technical-specification definition of operability. Other conditions are addressed under different processes that are tied to the regulations. Continuing the response, industry explained that the other processes; such as Corrective Action Program would be used to perform evaluations and track completion of issue resolution for items that do not meet the operability determination entry criteria. These other processes allow more time to do an evaluation but that site-specific procedures would get things into the right process with the right times for analysis, based on safety significance.
The NRC staff asked who would be responsible for answering the three required criteria questions in the operability-determination process. Industry said that the Senior Reactor Operator (SRO) would answer the questions. In addition, industry explained that the decision to put something into the operability determination process was done in the control room by senior licensed operators. Having the decisions made in the control room would help ensure the issue was placed in the right process and was analyzed in the correct time frame. The SRO always will retain the option to have a formal operability determination performed on any issue.
Continuing the questions, the NRC staff asked if the process had been piloted or run through a table-top exercise. The industry responded that the process had been back tested. Several plants from two different utilities had taken previously analyzed Condition Reports (CRs) or action requests and had senior reactor operators use the NEI entry criteria for the operability-determination process. Combined, over 2000 cases had been back tested.
Industry reported that the results from the entry criteria back testing for the operability determination reviews were consistent with the expected results from the condition report and action requests and resulted in an approximately 70% decrease in the number of documented immediate-operability determinations. The industry reinforced that should new or additional information become available, then either the entry criteria would be reconsidered or a new CR would be generated. The industry stated that this is consistent with current practices.
Additionally, the industry reported that the SROs who had been trained on the process and had back tested it found the operability-determination process a more logical and structured process.
The NRC staff also questioned how General Design Criteria (GDC) and pre-GDC plants were addressed. NEI responded that this would be covered in a future meeting. This was an action from the meeting.
A point raised by the NRC staff was that the quality of information going into the process affected the quality of the analysis. Industry stated that the same was true for the ongoing processes today. For example, the information on which CRs were developed affect the conclusions reached in the CRs. Therefore, industry did not see the quality of information as a unique issue for the operability-determination process.
D. Morey Discussions about NEI 18-03 centered on its use. One question asked by the NRC staff was to confirm that NEI 18-03 would not be submitted for NRC staff endorsement. NEI confirmed that NEI 18-03 was guidance for the industry and NRC staff endorsement was not being requested.
A second question on NEI 18-03 from the NRC staff was that NEI 18-03 only included approximately 30% of what was in IMC-0326. The NRC staff questioned if guidance for the remaining 70% of IMC 0326 would be developed. Industry said that NEI 18-03 dealt with the technical-specification definition of operability, and not all aspects of IMC 0326. As noted earlier in these notes, the industry stated that in every instance resolution of the issue would be addressed by the appropriate process.
The final topic discussed was the roll out of the process at plants. The NRC staff asked how that would be done. Industry explained that the roll out was still being developed and that this would be addressed at a future meeting. This was an action from this meeting.
The following are actions from the meeting:
- 1) NRC staff will provide some dates for the next meeting in approximately two weeks which will allow it to assess the information from this meeting;
- 2) At a future meeting, NEI will address: a) how GDC and non-GDC plants are handled; and b) how the process will be rolled out at plants.
Docket No.: 99902028
PKG ML18197A192 Summary ML18204A022 *concurrence via email NRC-001 OFFICE DLP/PLPB/PM* DSS/DD* DLP/PLPB/PM DLP/PLPB/PM NAME JHolonich JMarshall DMorey JHolonich DATE 09/18/2018 09/18/2018 09/27/2018 10/01/2018