ML18333A020
| ML18333A020 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18333A020 (2) | |
Text
Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP):
71130.14, Review of Power Reactor Target Sets Inspection Procedure Lead:
Stacy Prasad Date Completed:
10/05/2018 Estimated Hours to Complete Review:
5
- 1. Results and assessment of review of IMC 0308, ROP basis document review Credit is being given for this item because of recent IP effectiveness initiatives associated with the security baseline inspection program assessments (ML17223A279).
- 2. Results and assessment of review of any applicable changes to PIs Credit is being given for this item because of recent IP effectiveness initiatives associated with the security baseline inspection program assessments (ML17223A279).
- 3. Results and assessment of review of any applicable changes to Rules and STSs Credit is being given for this item because of recent IP effectiveness initiatives associated with the security baseline inspection program assessments (ML17223A279).
- 4. Results and assessment of review of recent Operating Experience Credit is being given for this item because of recent IP effectiveness initiatives associated with the security baseline inspection program assessments (ML17223A279).
- 5. Results and assessment of review based on RRPS data Adverse trends or outliers noted: Yes Review of Power Reactor Target Sets is a triennial inspection. The Summary of PIM Findings for calendar years (CY) 2013-2017 shows the number of findings identified were 4 in CY 2013, 1 finding in 2014, 5 findings in CY 2015, 10 findings in CY 2016, and 0 findings in CY 2017. Of the 20 findings issued, all 20 were identified by the inspector (100%). Of the 20 findings, all 20 were Green NCVs. During the 5 years, the findings per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> was 9.8 and the inspector identified per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> was 7.0. Reported hours show 459 hours0.00531 days <br />0.128 hours <br />7.589286e-4 weeks <br />1.746495e-4 months <br /> (5-year average) of the total allotted of 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> per year. The IP currently has a minimum inspection effort of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and a nominal inspection effort of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (note: this IP was revised in CY 2014 to reduce the number of inspection requirements and reduce the target range for completion, which was 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />). A review of the average inspection hours for the cycle identifies 8.53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br /> over the hours allotted per inspection. However, 38% of the hours for the 5-year span was charged in CY 2013, which skewed the average. If you average the hours after the IP requirements were reduced, the cycle identifies 7.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> over the hours allotted per inspection. This IP is consistently over utilizing the resources allotted.
In addition, there have been multiple changes that licensees have had to make that could affect target sets. This includes changes that have resulted from NEWFLEX mods, critical digital assets, and other changes, such as the NFPA 805, which affect target set element, locations, and groupings.
- 6. Feedback Forms Credit is being given for this item because of recent IP effectiveness initiatives associated with the security baseline inspection program assessments (ML17223A279).
- 7. Other Considerations Credit is being given for recent IP effectiveness initiatives associated with security baseline assessments (ML17223A279) for this item.
- 8. Results of discussions with regions All regions expressed concerns with the nominal hours assigned to this procedure and their ability to meet the inspection objectives. Since this is a triennial procedure, only having 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to review target set changes, target set maintenance, cyber considerations, and physical protection consideration is not adequate. This is supported by RRPS data that shows for each inspection, on average, an additional 7.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> is charged to complete the IP.
Recommendations Recommend adding 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 71130.14, Review of Power Reactor Target Sets,- hours would be gained from the 71130.06, Protection of Safeguards Information (SGI), which is a 6-hour inspection effort that is turning into an as needed inspection. This would raise the nominal hours from 10 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to give the inspectors sufficient time to perform samples and address deficiencies identified while implementing the 71130.14 procedure.