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 Mitigating Recommendation Consideration Strategy Aspect IMC 1202, Senior Add requirements to be familiar with use of FLEX at a site. Possible location to FLEX: Program Resident And Resident add is on checklists where it indicates to review site specific response for events Status Inspector Site Turnover involving a hurricane, earthquake, security, and fire.
IMC 2515, Light-Water Revise to add guidance for what may constitute a risk-informed FLEX inspection FLEX: Sample Reactor Inspection sample. Aspects of the discussion would address site specific PRA updates, as selection Program - Operations well as use of FLEX as a compensatory measure during outages, maintenances, guidance Phase or adverse weather conditions.
FLEX:
IMC 2515, Appendix D, Reasonable Revise to add language that the FLEX storage areas should be toured in a manner Plant Status protection of to that similar for ISFSIs.
equipment FLEX: Revise guidance to reiterate that any use of FLEX as a compensatory measure is Prepositioning for implemented as planned. Additional changes to guidance to (1) Update the diesel IP 71111.01, Adverse hazards with fuel oil guidance for Seasonal Extreme Weather Sample (section 03.02.d.6) to Weather Protection warning (flooding, add reference to FLEX diesels, (2) Update the credited operator action guidance severe weather, for External Flooding Sample (section 03.04.d) to add reference to FSGs, and (3) freeze protection) Update all guidance areas to reference NEI 12-06.
FLEX: Revise guidance to reiterate that any use of FLEX as a compensatory measure is IP 71111.13, Prepositioning for implemented as planned. Additional guidance would reiterate that IP 71111.12, Maintenance Risk outages / Maintenance Effectiveness or IP 71111.15, Operability Determinations and Assessments and maintenance Functionality Assessments could also be a consideration if FLEX was being used Emergent Work Control support a compensatory measure for a risk significant SSC / function.
IP 71111.15, Operability FLEX:
Revise to reference FLEX guidance (such as NEI 12-06) in the functionality Determinations and Reasonable discussion in the guidance section. One possible location would be in section Functionality protection of 03.02 at the start of the fifth paragraph.
Assessments equipment FLEX:
IP 71111.18, Plant Revise guidance to reiterate oversight of updates to FSGs if referenced risk Configuration Modifications significant equipment is modified.
control Enclosure 1
IMC / IP Under Mitigating Recommendation Consideration Strategy Aspect Revise guidance to reiterate that any use of FLEX as a compensatory measure is FLEX:
implemented as planned. Additional guidance would reiterate that IP 71111.12, IP 71111.20, Refueling Prepositioning for Maintenance Effectiveness or IP 71111.15, Operability Determinations and and Other Outage outages /
Functionality Assessments could also be a consideration if FLEX was being used Activities maintenance a compensatory measure for a risk significant SSC / function. One possible support location for the revised guidance is in section 03.01.a.1.
Revise the Mitigating Systems discussion in Table of section 03, Inspection IP 71111.22, FLEX: Equipment Guidance to add an example of when a FLEX sample may be considered.
Surveillance Testing" maintenance Changes to Requirements section likely needed as well due to change in Basis per IMC 308 Attachment 2.
FLEX:
The new IP would address oversight of configuration changes to FLEX SSCs and Configuration strategies.
control FLEX: Use of The new IP would address oversight of use of offsite resources.
Offsite Resources FLEX: Training The new IP would address oversight of training.
The new IP would address oversight of staffing. Focus should be on staffing FLEX: Staffing changes and could leverage verbiage found in TI 2515/191 and IP 71114.03, Emergency Response Organization Staffing and Augmentation System.
New beyond design The new IP would address oversight of communications. Focus should be minimal basis IP FLEX:
and cover communications not addressed in emergency planning. Verbiage in Communications Appendix C of TI 2515/191 could be leveraged.
(to be performed on a FLEX: Equipment The new IP would ensure oversight of equipment maintenance should FLEX be triennial or longer basis.
maintenance utilized as a defense in depth measure only per the order.
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:
Reasonable The new IP would ensure oversight of reasonable protection of equipment should protection of FLEX be utilized as a defense in depth measure only per the order.
equipment SAMG: The new IP would ensure oversight of SAMG configuration control (i.e. SAMGs Configuration updated when referenced equipment is modified & SAMGs updated when owner's control group develops new revision.
The new IP would ensure oversight of SAMG configuration control (i.e. SAMGs SAMG: Training updated when referenced equipment is modified & SAMGs updated when owner's group develops new revision.
2
IMC / IP Under Mitigating Recommendation Consideration Strategy Aspect Guidance section in new IP to have brief discussion on regulatory background.
Hardened SAMGs provide the venting strategy required to meet Order EA-13-109.
Containment Additional oversight of other aspects of hardened containment vent order not Vents warranted given performance of TI 2515/193.
FLEX: Equipment Covered by FLEX aspects of Equipment Maintenance and Reasonable Protection available / spare of Equipment.
equipment Identified issues can be addressed via existing procedures, as well as New FLEX: Drills beyond design basis IP proposal.
FLEX: Program Oversight of key aspects of FLEX have been addressed; no additional oversight No specific revisions as a whole considerations are warranted for program.
needed.
Multi-Source Licensee programs verified via TI 2515/191. Aspects considered low risk Dose significance & not likely to be modified going forward.
Assessment Focused Evaluations and Covered by existing IP 71111.01 & 71111.15, as well as New beyond design basis Integrated IP proposal.
Assessments 3
ROP Revisions to Address Regulatory Actions Taken Following the Fukushima Dai-Ichi Accident ADAMS Inspection Manual Chapter (IMC) Date of Effective Description Accession
/ Procedure (IP) Revised Publication Date No.
IMC 1202, Senior Resident And Revised to require tours of FLEX storage 06/28/2018 01/01/2019 ML18163A232 areas during site turnover.
Resident Inspector Site Turnover IMC 2515, Light-Water Reactor Guidance provided on FLEX sample Draft issued for comment in September selection during performance of baseline Inspection Program - Operations 2018. Awaiting finalization by IMC lead. ROP.
Phase Guidance provided that plant tours should IMC 2515, Appendix D, Plant occasionally include FLEX storage 11/19/2018 01/01/2019 ML18134A177 Status locations.
Guidance provided on oversight of licensee commitments to consider Severe Accident Management Guidelines (SAMGs) within plant configuration IP 71111.18, Plant Modifications 11/17/2016 01/01/2017 ML16306A185 management processes. IP revised prior to establishment of working group and in order to address SRM SECY-15-0065 (ML15239A767).
Revised to require oversight of licensee commitments to update site specific ML18176A157 SAMGs when the PWROG/BWROG IP 71111.18, Plant Modifications 11/19/2018 01/01/2019 issues revised generic severe accident technical guidelines. IP revised in order to address SRM SECY-15-0065.
Revised to allow for oversight of FLEX IP 71111.22, Surveillance Testing" 11/19/2018 01/01/2019 ML18177A109 testing, and as a minimum, require one FLEX inspection sample per year.
Enclosure 2