ML20078L380

Briefing on Agency Practice and Procedure Issues: NRC Expert Evaluation on Gas Transmission Lines, Indian Point

ML20078L380
Person / Time
Site:	Indian Point
Issue date:	03/18/2020
From:	NRC/EDO
To:
Clark T
References
Download: ML20078L380 (2)

Text

Briefing on Agency Practice and Procedure Issues:

U.S. Nuclear Regulatory Commission (NRC) Expert Evaluation Team on the Concerns Pertaining to Gas Transmission Lines at the Indian Point Nuclear Power Plant March 18, 2020 PURPOSE:

Respond to direction from the Executive Director for Operations (EDO) that [w]ith respect to modifications to agency practices or procedures, the team should inform the EDO of any issues identified in their evaluation within 20 days of [February 27, 2020,] to permit the EDO to assess and develop changes, if appropriate.

KEY MESSAGES:

The available evidence reviewed up to this point does not indicate a need for the NRC to take immediate regulatory action to assure the safety of Indian Point. The team continues to focus on plant and public safety as it completes its technical evaluations.

o The team is analyzing up-to-date pipeline failure data from the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA).

o Sandia National Laboratories is analyzing natural gas pipeline rupture phenomena and consequences.

o The team is assessing the robustness and significance of plant support equipment that could potentially be affected by a gas explosion or fire.

Based on the teams review to date of prior NRC activities related to the natural gas transmission pipeline near Indian Point, the team has identified four areas where NRC process issues should be further assessed.

o The quality of NRC technical work products, including peer reviews, may need to be strengthened.

Awareness and application of guidance in NRRs Office Instruction on technical work quality (NRR-ADM-405) should be improved.

Criteria for conducting peer reviews and the level of effort to be expended should be clarified.

Peer reviewer responsibilities and qualifications should be clarified.

o NRC guidance for obtaining technical support for inspections should be clarified.

Regulatory context and technical focus areas for the needed support should be explained to headquarters staff.

Task Interface Agreements may be appropriate, if expected effort is significant.

o The process for conducting 10 CFR 2.206 petition reviews should be revisited.

Centralization of leadership could improve consistency, knowledge, and flexibility.

Additional process training for those involved in petition reviews is warranted.

The team is evaluating additional potential improvements to the 10 CFR 2.206 process.

o Coordination between NRC and other Federal or State agencies should be strengthened.

Requests should be documented, with formal agreements where needed.

Inputs should be documented and made publicly available where appropriate.

Regulatory and technical context should be provided for each input offered.

2 ADDITIONAL INFORMATION:

As presented in the teams evaluation plan (ML20069A759), the team is focusing on:

1. the conclusions of the NRC safety analysis related to the 10 CFR 50.59 inspection in 2014,

2. the conclusions regarding a related 10 CFR 2.206 petition in 2015, and

3. agency practices or procedures relevant to the OIG event inquiry.

The previous page provides an early look at items from the third review area. The Executive Director for Operations may wish to consider initiating separate activities to address these issues while the team continues its evaluations.

The 45-day report to the Commission (due April 9, 2020) will address all three review areas, including the results of modeling by Sandia National Laboratories of natural gas pipeline rupture phenomena and consequences.

The following items summarize activities the team has undertaken to date.

Assembled team (including contract with Sandia National Laboratories) and issued evaluation plan publicly on March 9, 2020.

Conducted interviews with 15 staff and managers in Office of Nuclear Reactor Regulation (NRR) and Region I who were directly involved in the NRCs inspection, analysis, and petition review.

(Additional internal and external interviews are ongoing, including with the member of the public who raised issues with the pipeline through the 10 CFR 2.206 process.)

Reviewed numerous public and non-public references, including multiple NRC and Entergy analyses and external stakeholder concerns, and constructed a chronology of events.

Considered documents submitted by members of the public, as well as external interviews, in conducting the teams review; to the extent practical given compressed schedule.

Visited Indian Point site on March 12, 2020.

o Directly observed pipeline locations, plant safety systems, and equipment and structures that could be affected by a pipeline rupture.

o Interviewed Entergy staff members involved in evaluations of pipeline hazards.

Discussed details of Regulatory Guide 1.91 equations and references with fire experts in the Office of Nuclear Regulatory Research.

Initiated analyses (Sandia National Laboratories) of rupture phenomena and consequences.

In coordination with PHMSA team member, obtained additional information on pipeline operation (including isolation after rupture), physical layout, and safety requirements.