ML19274C665
| ML19274C665 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/2019 |
| From: | Chris Miller Division of Inspection and Regional Support |
| To: | |
| RAKOVAN L/NMSS/MSST | |
| Shared Package | |
| ML19274C654 | List: |
| References | |
| Download: ML19274C665 (15) | |
Text
Reactor Oversight Process (ROP) Enhancement Initiative Meeting with State Liaison Officers Chris Miller, Director Division of Inspection and Regional Support Office of Nuclear Reactor Regulation September 5, 2019
Regulatory Framework 2
ROP Simplified Cornerstones of Safety and Security Baseline Inspection Results Significance Threshold Action Matrix Significance Threshold Performance Indicator Results Regulatory Response 3
ROP Enhancement
Background
- Project initiated October 2018
- Internal and external drivers
- Goal is to better risk-inform and performance-base the ROP
- Designated team established with significant regional involvement 4
Extensive Public Outreach
- 14 public meetings with media interest and involvement
- Public Commission meetings in Fall 2018
- 2019 Regulatory Information Conference
- Involvement by Union of Concerned Scientists
- Federal Register Notice issued (84 FR 38675)
- Continued monthly public meetings scheduled for remainder of 2019 and beyond
- Public webpage developed https://www.nrc.gov/reactors/operating/oversight/rop-enhancement.html#keydocs 5
Baseline Inspection Program
- Numerous risk-informed and performance-based inspectable areas across all cornerstones
- Routinely performed by resident and regional inspectors
- Inspection samples and frequencies vary based on importance
- Strictly monitored to ensure completion
- Problem identification and resolution (PI&R) inspections are an essential cross-cutting activity
- ~ 3,000 inspection hours performed per year at each site 6
PI&R Inspections
- Numerous inspections are performed on a daily, semi-annual, annual and biennial frequency 7
Significance Determination Process (SDP)
- SDP used to determine significance of inspection findings and corresponding regulatory response 8
SDP Nomenclature Red (high safety significance)
Decline in performance that involves an unacceptable loss of safety margin Yellow (substantial safety significance moderate)
Decline in performance that is acceptable but with significant reduction in safety margin White (low to moderate safety significance low)
Acceptable level of performance, but outside the nominal risk range Green (very low safety significance)
Performance is acceptable with nominal risk and deviation 9
Major Themes
- Baseline inspection program
- Inspectable areas
- Sample sizes and hours
- Treatment of white findings and performance indicators
- IP 95001 level of effort
- Action Matrix mechanics
- Better risk-inform SDP
- EP planning standards
- SECY paper issued June 2019 seeking Commission approval (SECY-19-0067/ML19070A036) 10
Other Focus Areas
- Modify the descriptions of White and Yellow inspection findings and performance indicators to improve clarity
- Change Action Matrix to improve consistency
- Emphasize Office of Public Affairs guidance on issuance of press releases for White findings
- These changes do not require Commission approval 11
ROP Enhancement Phase 2
- Comprehensive review of PI&R Program
- Effectiveness review of the Cross-Cutting Issues Program
- Additional actions identified in EP focused self-assessment
- Radiation Protection and Independent Spent Fuel Storage Installation inspections
- Phase 2 scheduled to be completed in 2019 12
Longer Term Activities
- Continuously evaluate SDP to improve its accuracy, efficiency, and transparency
- Evaluate performance indicator program, including the Mitigating Systems Performance Index performance indicator, for improvements
- Modify engineering inspections 13
Final Thoughts
- ROP is a well-conceived, robust, and effectively implemented oversight program for nuclear reactors
- ROP enhancement aims to further improve the ROP taking into account improved industry performance and extensive experience since its implementation
- ROP enhancement is not a one and done project - more changes may be proposed
- All changes made to the ROP will be consistent with the NRC Principles of Good Regulation
- Significant changes will require Commission approval 14
Questions and Answers 15