ML20065M372

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Memo from Dro to Regional Divisional Directors - Establishment of Power-Operated Valve Cross Regional Panel
ML20065M372
Person / Time
Issue date: 03/10/2020
From: Chris Miller
NRC/NRR/DRO/IRIB
To: Dan Collins, Mark Franke, Ryan Lantz, Julio Lara, Mark Miller, O'Brien K, Anton Vegel
Division Reactor Projects I, Division of Reactor Safety I, Division Reactor Projects II, Division of Reactor Safety II, Division Reactor Projects III, Division of Reactor Safety III, NRC/RGN-IV/DRP, Division of Reactor Safety IV
Bollock D, NRR/DRO, 415-6609
References
Download: ML20065M372 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 10, 2020 MEMORANDUM TO: Those on the Attached List FROM: Christopher G. Miller, Director /RA/

Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUBJECT:

ESTABLISHMENT OF POWER-OPERATED VALVE CROSS REGIONAL PANEL PURPOSE:

The purpose of this memorandum is to document the establishment of a Cross Regional Panel to promote consistent application and resolution of inspection findings and proposed enforcement action identified during inspections of licensee Power Operated Valve (POV) programs per U.S. Nuclear Regulatory Commission (NRC) inspection procedure 711111.21N.02, Design Basis Capability of Power Operated Valves (POV) Under 10 CFR 50.55a Requirements.

BACKGROUND:

Beginning in calendar year 2020, the NRC will commence inspection of licensee POV programs using NRC inspection procedure 711111.21N.02, which is an area for which the NRC has not conducted focused inspection activities in several years. Because of the limited inspection experience in this area and mindful of lessons learned when implementing the Environmental Qualification inspections, a Power Operated Valve Cross Regional Panel that consists of technical experts from the Office of Nuclear Reactor Regulation and Branch Chiefs from each regional office in the Division of Reactor Safety has been established to assist inspectors in the evaluation and assessment of potential inspection findings and enforcement actions.

Establishment of such panels has proven to be an effective approach to ensure inspection issues are evaluated in a consistent and timely manner across the four Regional offices. This panel will follow the guidance outlined in a December 11, 2018, memorandum from CONTACT: Douglas R. Bollock, NRR/DRO (301) 415-6609

Christopher Miller, Director, Division of Reactor Inspection and Regional Support to the Directors of the Division of Reactor Projects and Safety in the Regional Offices.

(ML18232A192). Members of the panel are listed in Attachment (1) of this memo.

MEHODOLOGY:

The POV Cross Regional Panel will meet following the completion of each POV inspection and review all inspection findings, including minor violations, and proposed enforcement actions identified during the conduct of inspection activities prior to the issuance of the subject inspection report. Although the frequency and length of the meetings will be determined by the Board Chairperson or their designee, it is recommended to expedite the meeting decision process and minimize discussion time that all proposed findings should be provided to board members several working days in advance of the meeting date.

Proposed findings can be viewed by board members using Replacement Reactor Program System (RRPS) for the applicable inspection report under the Sites Directory or distributed to the board members using the template included in Attachment 2. All performance issues, e.g.

those that have been identified at the inspection exit meeting as minor or more than minor must be documented in the template or RRPS and discussed at the panel meeting. The template or RRPS entry should be completed by a knowledgeable inspector or the inspection team leader.

The panel chair will facilitate the discussion and help the panel reach consensus on the final disposition of the issue of concern, performance deficiency, and inspection finding. Similar to Significance Determination Process/Enforcement Review Panels (SERPs) consensus decision-making, unanimous agreement of the cross-regional panel voting members is not needed to establish consensus; rather, a consensus decision is one in which all members at least generally accept the position, agreement, or decision reached. Each panel member may question or challenge any of the information and analyses presented. If consensus is not reached at the conclusion of the panel, the issue will be elevated by the regional branch chief responsible for the inspection, to a discussion with the decision makers (regional (Division of Reactor Safety)/(Division of Reactor Projects) Division Directors or their designees, with the Division of Reactor Oversight Director/Deputy Director facilitating the decision making. For potentially greater than green issues, the SERP process will be followed (IMC 609, Attachment 1, Significance and Enforcement Review Panel (SERP) Process). The panels decision will serve as the final minor/more-than-minor determination for these performance deficiencies.

Following the meeting, the lead inspector or inspection team leader will document the final findings in RRPS and the inspection report in accordance with NRC policies and procedures.

The POV programmatic lead will document meeting minutes to capture final decisions made during the panel and save the minutes on a POV SharePoint site.

This POV panel is intended to be temporary and can be disbanded once there is sufficient familiarity and consistency with how to disposition such inspection findings and issues. This will be indicated when the panel provides little to no added value to the findings the inspectors have prepared. Disbanding of the panel will be at the discretion of the Director, Division of Reactor Oversight panel chairs.

Enclosure:

1. Attachment 1
2. Attachment 2 2

Those Attached on The List Daniel S. Collins Division of Reactor Projects, Region I Jimi T. Yeorkun Division of Reactor Safety, Region I Mark Miller Division of Reactor Projects, Region II Mark Franke Division of Reactor Safety, Region II Julio F. Lara Division of Reactor Projects, Region III Kenneth G. OBrien Division of Reactor Safety, Region III Anton Vegel Division of Reactor Projects, Region IV Ryan E. Lantz Division of Reactor Safety, Region IV 3

Attachment 1 Table 1: List of Participants Panel Member Role IRIB/IRAB Branch Chief or designee* * **Chair/Participant Regional DRS Branch Chief responsible for

  • Participant inspection or designee*

Inspection Team Leader or inspector

  • Presenter knowledgeable in the inspection and findings*

Other regional BCs and inspectors Observers/Participants Enforcement Representative, as needed Participant NRR technical leads for POV, as needed Participant Regional Senior Reactor Analyst, as needed Participant Regional Counsel, as needed Participant

  • required for quorum
    • only one DRO BC is required Enclosure 1

Attachment 2 Power-Operated Valve Panel Worksheet Note: RRPS in lieu of this worksheet.

Date of Panel Inspection Date Licensee Exit Date Region Report Number Lead Inspector Performance deficiency (including regulation or standard not met)

Brief summary of the issue Minor/more-than-minor (including basis) and proposed significance Cross-cutting aspect and basis(optional)

Enforcement (if applicable)

Comments Enclosure 2

SUBJECT:

ESTABLISHMENT OF POWER-OPERATED VALVE CROSS REGIONAL PANEL DATED MARCH 10, 2020 DISTRIBUTION:

RidsNrrDro RidsRgn1MailCenter RidsRgn2MailCenter RidsRgn3MailCenter RidsRgn4MailCenter ADAMS Accession No. ML20065M372 *via email OFFICE NRR/DRO/IRIB NRO/DRO/IRIB NRR/DRO NAME DBollock THipschman CMiller DATE 3/5/2020 3/5/2020 3/10/2020 OFFICIAL AGENCY RECORD 4