ML18333A045

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IP 71151 Assessment18
ML18333A045
Person / Time
Issue date: 04/24/2019
From: Aron Lewin
NRC/NRR/DIRS/IRIB
To:
Lewin A, 415-2259, NRR/DIRS
References
Download: ML18333A045 (4)
v • d • e


Text

Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP): IP 71151: Performance Indicator Verification Inspector Procedure Lead: Joylynn Quinones Estimated Hours to Complete Review: 24 hrs Date Review Completed: 9/14/18

1. Results and assessment of review of IMC 0308, ROP basis document review No changes at this moment to the ROP basis document.
2. Results and assessment of review of any applicable changes to PIs A three year review by the PI lead did not identify any significant changes to PIs that would result in a reduction or unintended gap in the key safety attributes of each safety cornerstone.
3. Results and assessment of review of any applicable changes to Rules and STSs Revisions to rules and Standard Technical Specifications within the last five years did not indicate a need for revision.
4. Results and assessment of review of recent Operating Experience Review of the Operating Experience within the last five years did not reveal a need for the IP to be revised.
5. Results and assessment of review based on RRPS data.

Trends noted: None a) NRC total and regional Findings per 1000 Inspection Hours Findings per 1000 Inspection Hours Findings / Findings / Findings / Findings / Findings / 5 Year 1000 hrs 1000 hrs 1000 hrs 1000 hrs 1000 hrs Findings (2013) (2014) (2015) (2016) (2017) /1000 hrs Region 1 4.2 1.5 1.8 1.5 2.2 2.3 Region 2 0.0 0.0 0.0 0.0 0.0 0.0 Region 3 2.9 0.0 4.5 1.4 0.0 1.8 Region 4 0.0 6.6 1.8 0.0 2.2 2.1 Total All 1.9 1.5 1.9 0.7 0.9 1.4 Regions

b) NRC total and regional Inspector Identified Findings per 1000 Inspection Hours Inspector Identified Findings per 1000 Inspection Hours Findings / Findings / Findings / Findings / Findings / 5 Year 1000 hrs 1000 hrs 1000 hrs 1000 hrs 1000 hrs Findings (2013) (2014) (2015) (2016) (2017) /1000 hrs Region 1 4.2 1.5 0.0 1.5 0.0 1.6 Region 2 0.0 0.0 0.0 0.0 0.0 0.0 Region 3 2.9 0.0 4.5 0.0 0.0 1.5 Region 4 0.0 6.6 1.8 0.0 0.0 1.7 Total All 1.9 1.5 1.5 0.4 0.0 1.1 Regions c) NRC total and regional HRS/Samples The PIs for Initiating Events, Mitigating Systems, and Barrier Integrity are completed per unit while the PIs for Emergency Preparedness, Occupational Radiation, and Public Radiation are completed per site. As a result, the following breakdown occurs:

1 Unit sites (24 sites for a total of 24 units): 17 PIs inspected per site 2 Unit sites (33 sites for a total of 66 units): 28 PIs inspected per site 3 Unit sites (03 sites for a total of 09 units): 39 PIs inspected per site The procedure resource estimate for this procedure is divided by the amount of units per site:

2013 2014 2015 2016 2017 Hours/Units Reported Reported Reported Reported Reported Units/Site (5 yr Avg) hours/# hours/# hours/# hours/# hours/#

Units Units Units Units Units 1 23.19 23.25 23.41 23.16 27.71 18.42 2 25.56 26.75 26.24 26.5 26.3 22.7 3 37.84 44.88 38.44 33.22 42.44 30.55 Inspectors on average have stayed close to the allotted inspection hours in the resource estimate in the last 5 years.

d) Traditional Enforcement violations identified in the Summary of PIM Findings The review revealed 4 items in the PIM that were processed through Traditional Enforcement and were associated with IP 71151. They were all SL IV.

RI: 2015 - Susquehanna (ML13134A117) 2016 - Calvert Cliffs SL IV NCV (ML16216A317)

RIII: 2013 - Prairie Island (ML13134A360)

RIV: 2015 - ANO SL IV NOV (ML15117A663) e) Color of findings identified in the Summary of PIM Findings: 10 issues were identified in the last 5 years in RRPS under procedure IP 71151, but two of those issues were included in the inspection reports under IP 71152. Below the breakdown.

Susquehanna - ML15309A092 - reported under IP 71152), one SVL IV - NCV (Calvert Cliffs - ML16216A317), one Green Finding with SVL IV (Susquehanna Self-Revealing - ML13134A117)

  • Region II: No issues identified during this period
  • Region III: Two Green Findings (DC Cook - ML16039A333 & Prairie Island -

ML13134A360), two Green NCVs (Perry Self Revealing - ML17041A069 & Prairie Island - ML13134A360 with TE SL IV)

Discuss any greater than green findings or greater than Severity Level IV violations: None documented in last 5 years

6. Feedback Forms 71151-1956 - Feedback form from 2012 requesting additional hours. Working on the resolution of this feedback form as part of the back log FBF project.

71151-1786 - Feedback form from 2011 requesting a modification on the IP guidance.

Working on the resolution of this feedback form as part of the back log FBF project.

0308.1-1651 - Feedback form from 2007 and 2008. Working on the resolution of this feedback form as part of the back log FBF project.

7. Other Considerations None.
8. Results of discussions with regions RI - talk on 9/12/2018 RII - talk on 9/11/2018 RIII - no response RIV - feedback received on 10/15/2018

Recommendations No specific recommendation received, but two of the regions (RI and RII) had the same question are we looking at the right PIs?

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