ML18338A463

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IP 71114 Assessment 37
ML18338A463
Person / Time
Issue date: 04/24/2019
From: Aron Lewin
NRC/NRR/DIRS/IRIB
To:
Lewin A, 415-2259, NRR/DIRS
References
Download: ML18338A463 (8)
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2018 IMC 307 Inspection Procedure Assessment Summary Inspection Procedure (IP): IP-71114 Reactor Safety Emergency Preparedness Inspector Procedure Lead: Eric Schrader Estimated Hours to Complete Review: 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Date Review Completed: September 25, 2018

1. Results and assessment of review of IMC 0308, ROP basis document review The objectives of Inspection Procedure 71114 as described in IMC 0308, Attachment 2 are accomplished through successful completion of the following eight IP 71114 attachments:
  • .01 Exercise Evaluation
  • .02 Alert and Notification System Testing
  • .06 Drill Evaluation
  • .07 Exercise Evaluation - Hostile Action (HA) Event
  • .08 Exercise Evaluation - Scenario Review A review and update of each EP IP Basis Summary Sheet was performed in November of 2017. The objectives and requirements of the current inspection procedure attachments described above were reviewed against the recently revised basis applicable IMC 308 Attachment 2 basis summary sheets. This review concluded the ROP EP fundamental inspection elements defined in IMC 0308 and supporting documents, continue to be maintained.

The last revision to all eight attachments of IP 71114 was completed and issued in July of 2016.

2. Results and assessment of review of any applicable changes to PIs A review of changes and FAQs affecting the emergency preparedness PI over the past 3-year found no changes and one EP FAQ submitted, approved and made effective in November of 2015. The FAQ (FAQ 15-04) requested clarification for granting participation credit in a HAB Drill/Exercise. FAQ 15-04 was made effective 11/17/2015 and has not created nor identified any reductions or unintended gaps in the key safety attributes of the EP cornerstone.

Additionally, a 3-year look-back at approved FAQs and the last revision of NEI 99-02 (Rev. 7 published in August 2013) was performed by the NRR Performance Indicator Lead. This review also found no significant changes to PIs that resulted in a reduction or unintended gap in the key safety attributes of each of the ROP safety cornerstones.

3. Results and assessment of review of any applicable changes to Rules and STSs A review of revisions made to rules and Standard Technical Specifications over the last three years did not identify any issues affecting IP 71114 or Attachments .01 thru .08.
4. Results and assessment of review of recent Operating Experience A review of recent Operating Experience data did not identify any issues that would affect IP 71114 or attachments. Prior Operating experience captured in IP 71114 and Attachments remains pertinent.
5. Results and assessment of review based on RRPS data No Adverse trends or outliers were noted during the assessment RRPS data supporting the performances IP 71114.01 through 71114.08.

Inspection Findings Analysis During time frame from CY2015 to CY2017, there were a total of 51 findings and violations associated with the EP cornerstone 28 through the performance of the eight attachments to IP 71114 and 23 thru other IPs. The findings and violations break down as follows:

1 Green Finding 1 Green Violations 41 Green Non-Cited Violations 3 Severity Level IV Non-Cited Violation 1 Severity Level IV Violation 0 Severity Level III 4 White Violations 51 Total findings and violations Due to an issue with the number of inspection hours documented in HRMS versus the actual number of inspection hours used by inspectors performing IP 71114 and attachments for the CY2015 to CY2017 review period, the Findings/1000 hours assessment will not be performed. The issue has been reported to the RPS Support Resource group and is being investigated, however remains unresolved at this time. This issue has been discussed with the IMC 0307B Assessment lead and a determination made to perform an assessment of findings and violations per inspection procedure per year instead of findings per 1000 inspection hours. See Table 1 Total Findings/Violations ROP and Traditional Enforcement (TE) by IP and Year for a breakdown of findings/violation for each IP 71114 attachment and other IPs (that have identified EP inspection issues) over the past three years.

Special Inspections There were four special inspections performed under the EP cornerstone over the past three years. The special inspections were conducted in accordance with IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs as follows:

  • 02/24/2017 Fermi - Failure to maintain a dose assessment process capable of technically accurate projected offsite doses and PARs for a rapidly progressing accident
  • 06/30/2016 Ginna - For making an incorrect revision to the EAL fission product barrier matrix for a potential loss of containment barrier.
  • 02/08/2017 Vogtle - An EAL threshold value transposition error resulting in the setpoint being off by approximately a factor of forty-two.
  • 03/18/2015 SUSQ Failure to ensure timely event declaration for an unisolable primary system leak due to a misinterpretation of the 15-minute assessment and classification period For a summary of PIM Findings/Violations for ROP and Traditional Enforcement from 2013 thru 2017 see Table 2 Findings/Violations per Year per Inspection Procedure.

To address a Commission question to management for the cause of a drop in Findings particularly around 2013 see Figure 2 Total Findings/Violations All IPs by Year.

Figure 2 shows:

  • The total number of findings and violations identified in the EP cornerstone from 2000 thru 2017 by all inspection procedures that have identified an EP cornerstone finding or violation during this time period.
  • An overall decreasing trend in findings and violations from 2000 to 2017, and
  • The decrease in 2013 is not significantly different from the many other decreases shown on the graph, therefore there is no concern needing further investigation.
6. Feedback Forms There are currently no open feedback forms affecting IP 71114 or Attachments .01 thru .08.

A review of closed feedback forms submitted against IP 71114 or its attachments over the last 3-years found two closed feedback forms. Both feedback forms were written against IP 71114.06 Drill Evaluation. The following is a summary of the two feedback forms:

  • Feedback form 71114-06-1952 - requested the correction of an editorial error made in the first note under section 03.03 where it states Poor performance in a drill is not a regulatory issue if the licensee corrects the performance issue or enters it into its CAP.

The DEP PI captures performance failures and unless the PI crosses the green band threshold then increased NRC involvement is warranted. The correction requested was to change is warranted to is not warranted and was approved.

  • 71114.06-1952 - requested the current minimum inspection sample size definition of 3 observations consisting of 1 EP drill and 2 additional drills and/or training evolutions, be revised to allow completion of inspection procedures 71114.01 or 71114.07 to count as 1 of the EP drill samples. This request was denied.
7. Other Considerations The Policy and Oversight Branch (POB) is beginning an evaluation of the Emergency Preparedness Inspector training offered and the Emergency Preparedness Inspector Technical Proficiency Training and Qualification Journal. Part of this evaluation will be a review of IP 71114 and each of the attachments by both headquarters and regional inspectors to ensure each of these three pieces are coordinated and that each of the EP regulatory requirements are appropriately addressed in the inspector training, qualifications and inspection procedures.
8. Results of discussions with regions The POB has the following types of continuous contact and discussions with regional EP inspectors to, in part, discuss IP attachments implementation, scope and assigned resources:
  • A monthly EP counterpart call is conducted with regional inspectors to discuss headquarters and regional personnel changes/rotations, reactors licensing branch updates, regional inspection activities, headquarters project/initiatives and outreach activities planned or in progress.
  • Each member of the POB is expected to at least once annually to observe in person the implementation of the EP inspection program in one of the regions Recommendations There are no current significant inspection procedure implementation observations that would warrant a procedure revision. The IP attachments are currently working as intended.

There are currently no changes proposed to any of the inspection procedures or their assigned resources. No additional training has been identified.

Table 1 - Total Findings/Violations ROP and Traditional Enforcement (TE) by IP and Year 2015 2016 2017 IP 71114 ROP Finding Color TE ROP Finding Color TE ROP Finding Color TE

.01 0 N/A 0 0 N/A 0 1 1-Green NCV 0

.02 0 N/A 0 0 N/A 0 0 N/A 0

.03 1 1-Green NCV 0 2 Green NCV 0 0 N/A 0 1-SL-IV NCV 2-Green NCV

.04 2 2-Green NCV 3 0 0 N/A 0 1-SL-IV 1-White Vio

.05 3 3-Green NCV 0 4 4-Green NCV 0 3 3-Green NCV 0

.06 1 1-Green NCV 0 3 3-Green NCV 0 1 1-Green NCV 0

.07 1 1-Green NCV 0 0 N/A 0 0 N/A 0

.08 0 N/A 0 0 N/A 0 0 N/A 0 IP 71114 10 N/A 2 12 N/A 0 5 N/A Total 11-Green NCV 1-SL-IV NCV 4-Green NCV 2-Green NCV Other IPs 15 1-Green Vio 5 0 4 0 1-SL-IV NOV 1-Green finding 2-White Vio 1-White Vio Total per 25 17 9 year

Figure 1 - Inspection Findings/Violations Per Year Per IP 71114.01 thru .08 and Other IPs 25 71114.01 71114.02 71114.03 71114.04 20 71114.05 71114.06 71114.07 71114.08 15 Other IPs Total Findings/Violations 10 5

0 2015 2016 2017

Table 2 - Findings/Violations per Year per Inspection Procedure 2013 2014 2015 2016 2017 71114.01 3 0 0 0 1 71114.02 1 0 0 0 0 71114.03 0 0 1 2 0 71114.04 0 0 4 3 0 71114.05 2 9 3 4 3 71114.06 1 2 1 3 1 71114.07 0 1 1 0 0 71114.08 0 0 0 0 0 IP 71114 totals 7 12 10 12 5 Other IP totals 13 22 15 5 4 Total Findings/Violations 20 34 25 17 9

Figure 2 - Total Findings/Violations All IPs by Year Number of Findings/Violations 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Year Findings/Violations All IPs Linear (Findings/Violations All IPs)

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