ML18352A888
| ML18352A888 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/2019 |
| From: | Thomas Hipschman NRC/NRR/DIRS/IRIB |
| To: | Chris Miller Division of Inspection and Regional Support |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18352A888 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 8, 2019 MEMORANDUM TO:
Christopher G. Miller, Director Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM:
Thomas R. Hipschman, Branch Chief Reactor Inspection Branch /RA/
Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
COMPLETION OF WORKING GROUP ACTIVITIES TO UPDATE THE REACTOR OVERSIGHT PROCESS FOR REGULATORY ACTIONS TAKEN FOLLOWING THE FUKUSHIMA DAI-ICHI ACCIDENT The purpose of this memorandum is to document completion of working group activities associated with updating the Reactor Oversight Process (ROP) for regulatory actions taken following the Fukushima Dai-Ichi accident. A working group was established on October 12, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17164A285), and consisted of members from both the program office and the regions.
Numerous internal and external stakeholders have been involved throughout the process. The working groups recommendations are found in Enclosure 1 and were previously presented to the Nuclear Regulatory Commission (NRC) management in meetings held in May and June, 2018. Based on NRC management feedback, revisions to the ROP to address regulatory CONTACT:
Aron Lewin, NRR/DIRS 301-415-2259
C. Miller 2
actions taken following the Fukushima Dai-Ichi accident are found in Enclosure 2. During working group and management meetings, there were discussions on what would be the appropriate level of oversight for actions taken following the Fukushima Dai-Ichi accident. The revisions to the ROP found in Enclosure 2 represents a consensus outcome of those discussions. Normal ROP feedback processes can be utilized in the future should oversight issues be identified. As a result of the ROP being updated, the goals of the working group charter have been completed.
Therefore, the working group is being disbanded.
Enclosure:
- 1. ROP / Fukushima Working Group Recommendations
- 2. ROP Revisions to Address Regulatory Actions Taken Following the Fukushima Dai-Ichi Accident
OFFICE NRR/DIRS/IRIB NRR/DIRS/IRIB/BC NAME ALewin THipschman DATE 12/20/18 2/8/19
ROP / Fukushima Working Group Recommendations IMC / IP Under Consideration Mitigating Strategy Aspect Recommendation IMC 1202, Senior Resident And Resident Inspector Site Turnover FLEX: Program Status Add requirements to be familiar with use of FLEX at a site. Possible location to add is on checklists where it indicates to review site specific response for events involving a hurricane, earthquake, security, and fire.
IMC 2515, Light-Water Reactor Inspection Program - Operations Phase FLEX: Sample selection guidance Revise to add guidance for what may constitute a risk-informed FLEX inspection sample. Aspects of the discussion would address site specific PRA updates, as well as use of FLEX as a compensatory measure during outages, maintenances, or adverse weather conditions.
IMC 2515, Appendix D, Plant Status FLEX:
Reasonable protection of equipment Revise to add language that the FLEX storage areas should be toured in a manner to that similar for ISFSIs.
IP 71111.01, Adverse Weather Protection FLEX:
Prepositioning for hazards with warning (flooding, severe weather, freeze protection)
Revise guidance to reiterate that any use of FLEX as a compensatory measure is implemented as planned. Additional changes to guidance to (1) Update the diesel fuel oil guidance for Seasonal Extreme Weather Sample (section 03.02.d.6) to add reference to FLEX diesels, (2) Update the credited operator action guidance for External Flooding Sample (section 03.04.d) to add reference to FSGs, and (3)
Update all guidance areas to reference NEI 12-06.
IP 71111.13, Maintenance Risk Assessments and Emergent Work Control FLEX:
Prepositioning for outages /
maintenance support Revise guidance to reiterate that any use of FLEX as a compensatory measure is implemented as planned. Additional guidance would reiterate that IP 71111.12, Maintenance Effectiveness or IP 71111.15, Operability Determinations and Functionality Assessments could also be a consideration if FLEX was being used a compensatory measure for a risk significant SSC / function.
IP 71111.15, Operability Determinations and Functionality Assessments FLEX:
Reasonable protection of equipment Revise to reference FLEX guidance (such as NEI 12-06) in the functionality discussion in the guidance section. One possible location would be in section 03.02 at the start of the fifth paragraph.
IP 71111.18, Plant Modifications FLEX:
Configuration control Revise guidance to reiterate oversight of updates to FSGs if referenced risk significant equipment is modified.
2 IMC / IP Under Consideration Mitigating Strategy Aspect Recommendation IP 71111.20, Refueling and Other Outage Activities FLEX:
Prepositioning for outages /
maintenance support Revise guidance to reiterate that any use of FLEX as a compensatory measure is implemented as planned. Additional guidance would reiterate that IP 71111.12, Maintenance Effectiveness or IP 71111.15, Operability Determinations and Functionality Assessments could also be a consideration if FLEX was being used a compensatory measure for a risk significant SSC / function. One possible location for the revised guidance is in section 03.01.a.1.
IP 71111.22, Surveillance Testing" FLEX: Equipment maintenance Revise the Mitigating Systems discussion in Table of section 03, Inspection Guidance to add an example of when a FLEX sample may be considered.
Changes to Requirements section likely needed as well due to change in Basis per IMC 308 Attachment 2.
New beyond design basis IP (to be performed on a triennial or longer basis.
Overall effort would be around 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.)
FLEX:
Configuration control The new IP would address oversight of configuration changes to FLEX SSCs and strategies.
FLEX: Use of Offsite Resources The new IP would address oversight of use of offsite resources.
FLEX: Training The new IP would address oversight of training.
FLEX: Staffing The new IP would address oversight of staffing. Focus should be on staffing changes and could leverage verbiage found in TI 2515/191 and IP 71114.03, Emergency Response Organization Staffing and Augmentation System.
FLEX:
Communications The new IP would address oversight of communications. Focus should be minimal and cover communications not addressed in emergency planning. Verbiage in Appendix C of TI 2515/191 could be leveraged.
FLEX: Equipment maintenance The new IP would ensure oversight of equipment maintenance should FLEX be utilized as a defense in depth measure only per the order.
FLEX:
Reasonable protection of equipment The new IP would ensure oversight of reasonable protection of equipment should FLEX be utilized as a defense in depth measure only per the order.
SAMG:
Configuration control The new IP would ensure oversight of SAMG configuration control (i.e. SAMGs updated when referenced equipment is modified & SAMGs updated when owner's group develops new revision.
SAMG: Training The new IP would ensure oversight of SAMG configuration control (i.e. SAMGs updated when referenced equipment is modified & SAMGs updated when owner's group develops new revision.
3 IMC / IP Under Consideration Mitigating Strategy Aspect Recommendation Hardened Containment Vents Guidance section in new IP to have brief discussion on regulatory background.
SAMGs provide the venting strategy required to meet Order EA-13-109.
Additional oversight of other aspects of hardened containment vent order not warranted given performance of TI 2515/193.
No specific revisions needed.
FLEX: Equipment available / spare equipment Covered by FLEX aspects of Equipment Maintenance and Reasonable Protection of Equipment.
FLEX: Drills Identified issues can be addressed via existing procedures, as well as New beyond design basis IP proposal.
FLEX: Program as a whole Oversight of key aspects of FLEX have been addressed; no additional oversight considerations are warranted for program.
Multi-Source Dose Assessment Licensee programs verified via TI 2515/191. Aspects considered low risk significance & not likely to be modified going forward.
Focused Evaluations and Integrated Assessments Covered by existing IP 71111.01 & 71111.15, as well as New beyond design basis IP proposal.
ROP Revisions to Address Regulatory Actions Taken Following the Fukushima Dai-Ichi Accident Inspection Manual Chapter (IMC)
/ Procedure (IP) Revised Date of Publication Effective Date ADAMS Accession No.
Description IMC 1202, Senior Resident And Resident Inspector Site Turnover 06/28/2018 01/01/2019 ML18163A232 Revised to require tours of FLEX storage areas during site turnover.
IMC 2515, Light-Water Reactor Inspection Program - Operations Phase Draft issued for comment in September 2018. Awaiting finalization by IMC lead.
Guidance provided on FLEX sample selection during performance of baseline ROP.
IMC 2515, Appendix D, Plant Status 11/19/2018 01/01/2019 ML18134A177 Guidance provided that plant tours should occasionally include FLEX storage locations.
IP 71111.18, Plant Modifications 11/17/2016 01/01/2017 ML16306A185 Guidance provided on oversight of licensee commitments to consider Severe Accident Management Guidelines (SAMGs) within plant configuration management processes. IP revised prior to establishment of working group and in order to address SRM SECY-15-0065 (ML15239A767).
IP 71111.18, Plant Modifications 11/19/2018 01/01/2019 ML18176A157 Revised to require oversight of licensee commitments to update site specific SAMGs when the PWROG/BWROG issues revised generic severe accident technical guidelines. IP revised in order to address SRM SECY-15-0065.
IP 71111.22, Surveillance Testing" 11/19/2018 01/01/2019 ML18177A109 Revised to allow for oversight of FLEX testing, and as a minimum, require one FLEX inspection sample per year.