ML20322A191

Summary of the Reactor Oversight Process Monthly Public Meeting Held on October 28, 2020

ML20322A191
Person / Time
Issue date:	11/17/2020
From:	Tekia Govan NRC/NRR/DRO/IRAB
To:	Masters A NRC/NRR/DRO/IRAB
Tekia Govan, NRR/DRO/IRAB, 301-415-6197
References
Download: ML20322A191 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 17, 2020 MEMORANDUM TO:

Anthony D. Masters, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:

Tekia V. Govan, Project Manager /RA/

Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUMMARY

OF THE REACTOR OVERSIGHT PROCESS MONTHLY PUBLIC MEETING HELD ON OCTOBER 28, 2020 On October 28, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with the Nuclear Energy Institutes (NEIs) Reactor Oversight Process (ROP) Task Force executives, and other senior industry executives, to discuss the staffs progress on the ROP initiatives. The topics discussed during this teleconference are described below.

Status of Power-Operated Valve Inspections The NRC staff provided an update on an upcoming public meeting, to be held on December 8, 2020, to discuss lessons learned over the past year in conducting Inspection Procedure (IP) 71111.21N.02 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements (POV) inspections.

Performance Indicator (PI) Frequently Asked Questions (FAQ)

FAQ 20-02: Emergency Procedure (EP) 02, Emergency Response Organization (ERO) Drill Participation On April 15, 2020, FAQ 20-02 was discussed (ADAMS Accession No. 20106D694), transitioned to Final Approved status (ADAMS Accession No. ML20107F675), and became effective immediately. FAQ 20-02 addresses the impact to the ERO PI of deferred EP drills and exercises due to the COVID-19 public health emergency. The extension statement says, in part: For the COVID-19 event, holders of ERO key positions with end dates on or prior to September 30, 2020, may have their ERO-PI end date extended to December 31, 2020.

CONTACT: Tekia V. Govan, NRR/DRO 301-415-6197

During this meeting, the NRC staff discussed with industry the need to revisit the approved extension. As a result, NEI will revise FAQ 20-02 to propose a new end date. This FAQ will be discussed at the next ROP public meeting. The staff and members from the nuclear industry also discussed the potential impact that an extension on FAQ 20-02 would have on the completion of baseline IP 71151, Performance Indicator Verification. If the extension to FAQ 20-02 is granted, the NRC staff will assess any impacts on the IP.

FAQ 20-03: Generic - Restoration of Train Monitoring After PRA Model Changes On August 26, 2020, NEI presented FAQ 20-03 which proposes that when restoring trains/segments to mitigation system performance index (MSPI) monitoring, unavailability data be required only moving forward, including the quarter in which monitoring is restored ADAMAS Accession No ML20223A373). At this meeting, the NRC staff requested some examples that would provide details of what was being proposed in FAQ 20-03. NEI provided these examples via email (ADAMS Accession No. ML20288A499).

During this meeting, the NRC staff discussed the status of their review of PI FAQ 20-03. Based on its review, the staff raised the idea of a higher threshold in which a three-year review for MSPI data would be required based on the greater potential for a component with a higher Birnbaum value to affect the MSPI outcome. Industry indicated there may be merit to the idea. Further discussion on the topic may occur as part of developing a proposed FAQ response.

FAQ 20-04: Crediting Automated Notifications in the DEP Performance Indicator - Proposed NRC Response The NRC staff presented a proposed response FAQ 20-04, in which the nuclear industry proposed to add a sentence in the NEI 99-02 guidance to clarify the timeliness criterion for notifications made using a computer application to send an electronic message (ADAMS Accession No. ML20296A325). Based on the nuclear industry accepting the proposed response, FAQ 20-04 was transitioned to Tentatively Approved status (ADAMS Accession No. ML20309A621) and will be discussed at the next ROP meeting to transfer the FAQ to Final Approved status.

FAQ 20-05: River Bend Station (RBS) Unplanned Scram May 2019 Entergy staff presented FAQ 20-05 that describes an event that occurred on May 31, 2019 while RBS was shutting down to repair an A 5th Point Heater tube leak (ADAMS Accession No. ML20288A404). The alignment used for the shutdown caused several situations in which the operators ended up inserting a manual scram following a loss of suction to the A & C FW pumps. RBS classified this event as an Unplanned Scram per 7,000 critical hours. The resident inspectors believe that this event should be classified as an unplanned scram with complications following the flow charts within the NEI 99-02 guidance.

The NRC staff accepted the FAQ 20-05 for review and will have a proposed response in a future public meeting.

Inspection Procedure (IP) 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection The NRC staff discussed their working group activities to enhance IP 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection, (ADAMS Accession No. ML20192A322). Stakeholders were also made aware of the working groups charter (ADAMS Accession No. ML20182A687). The purpose, objectives, scope, and key milestones of the charter were discussed.

Modification of the Description of Unplanned Scrams with Complications Performance Indicator to Reflect AP1000 Design NEI submitted a whitepaper for the NRC staffs review entitled, Modification of the Description of Unplanned Scrams with Complications Performance Indicator to Reflect AP100 Design (ADAMS Accession No. ML20274A258). The NRC staff reviewed the whitepaper in anticipation of this meeting and were ready to discuss some questions regarding the proposal. Specifically, the NRC staff requested a clarification for the loss of power question.

It was proposed by NEI to exclude loss of power to the non-battery-backed uninterruptible power system (IDS) buses (e.g., IDSA-EA-2). This would be acceptable although the NRC asked to clarify the Class 1E instrument and control power buses would be included because power to the Class 1E instrument and control power buses (e.g., IDSA-EA-1) would need to be available/restored from the inverters powered by the battery-supplied dc switchboard if not from the non-battery-backed IDS buses. Licensee representative accepted the NRC comment and agreed to submit a revised version of the whitepaper with the changes for our review and discussion in a future public meeting.

Supplemental Inspection Procedure The NRC staff discussed the recent process enhancements published in Inspection Manual Chapter (IMC) 2515, Appendix B, Supplemental Inspection Program, IMC 0611, Appendix C, Guidance for Supplemental Inspection Reports, and IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. The presentation materials for this discussion can be found under ADAMS Accession No. ML20295A347.

Cross Cutting Issues The NRC staff provided a brief summary of the cross-cutting issues (CCI) program effectiveness review (ADAMS Accession No. ML20297A253), which is documented in a report available in ADAMS Package Accession No. ML20239A806. The package also contains background and supporting information for the report. The review provided an assessment of the CCI program and recommendations, for NRC managements consideration, to increase the efficiency and effectiveness of the CCI program. Further public engagement would occur should NRC management decide to pursue any of the recommendations.

Problem Identification and Resolution The NRC staff presented the status of the Problem Identification and Resolution (PI&R) comprehensive review, as documented in IP 71152, Problem Identification and Resolution. The comprehensive review began after the submittal of SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process in June 2019 (ADAMS

Accession No. ML19070A036). A 14-member team of NRC headquarters staff and regional inspectors performed the review consistent with the team charter (ADAMS Accession No. ML19212A017). Key objectives of the review:

ensure the purpose of the inspection is well defined to accomplish its objectives, ensure there is consistency in execution and documentation across the regions, make better use of risk insights and integrating them into other inspections and the annual End of Cycle assessment, and provide clearer criteria for inspectors and regional management to use when determining if a licensees PI&R processes including corrective action programs are ineffective or has substantial weaknesses.

The team has prepared a draft report of the review that will be publicly available. Prior to issuance of the report, it will be reviewed internally by NRC staff and the various options developed by the NRC team and NRC managements preferences for implementation will then be discussed with nuclear industry representatives and members of the public. The report is anticipated to be ready for public engagement in the first calendar quarter of 2021.

Operator Performance Trend The NRC staff discussed its observation that there have been an elevated number of events caused by lapses in operator fundamentals since 2017 (ADAMS Accession No. ML20297A361). The staff discussed some of these events at a high level, focusing on those that resulted in plant trips (automatic protective shutdowns). Previous industry and NRC actions, such as NRC issued Information Notices and the Institute of Nuclear Power Operations (INPO) Event Reports, have not effectively addressed the issue. The NRC staff is considering additional action and opened the topic for discussion in this public forum.

Update on FLEX Operator Experience Smart Sample The NRC staff provided a brief update on the IP for Operating Experience Smart Sample -

FLEX Equipment Design Control, Maintenance, and Testing, which was issued October 2020.

This IP can be found in ADAMS under Accession No. ML20220A261.

Significance Determination Process (SDP) Update, IMC 0609, Appendix A, At-Power SDP The NRC staff discussed the proposed revisions to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power and its basis document, IMC 0609, Attachment 3, Appendix A, Technical Basis for the At-Power Significance Determination Process. The NRC staff provided a summary of the proposed revisions to the loss of coolant accident initiator, fuel cladding integrity, and FLEX screening questions in IMC 0609 Appendix A (ADAMS Accession No. ML20295A269). The NRC staff also discussed that the basis document is being revised to add a basis for each of the screening questions. Industry expressed their desire to review the proposed revision to IMC 0609, Appendix A, before issuance. Therefore, the proposed revisions to IMC 0609, Appendix A, and IMC 0609, Attachment 3, Appendix A, are publicly available under ADAMS Accession Nos. ML20308A592 and ML20308A601, respectively, for discussion at the November 2020 ROP monthly public meeting.

SDP Update, IMC 0609, Appendices C and D, Radiation Protections SDPs The NRC staff provided highlights from a public meeting that was held on October 21, 2020 to discuss updates to the Radiation Safety Significance Determination Process documents. Details of the October 21, 2020 meeting can be found under ADAMS Accession No. ML20294A186.

Meeting Action Items

1. NEI committed to resubmitting a revision for PI FAQ 20-02. This revision will be discussed at the next ROP meeting.

2. NEI agreed to resubmit whitepaper for the NRC staffs review entitled, Modification of the Description of Unplanned Scrams with Complications Performance Indicator to Reflect AP100 Design. The submittal will address some of the NRC staffs comments discussed during this meeting.

3. During the October ROP meeting, the staff received two questions from Tony Zimmerman of Duke Energy. Below are the staffs responses to those questions below.

Question 1: In the past, a common cause for failing to successfully complete a 9500x inspection was that the NRC felt the licensee failed to adequately assess the full Extent of Condition or Extent of Cause. NEI/Industry and NRC had dialogue at the start of phase 2 of ROP Enhancement that there may be benefit in considering what constitutes an appropriate scope for an Extent of Condition or Cause review.

NRC Response 1: The primary source of NRC governance explicitly addressing extent-of-condition and extent-of-cause inspection for Action Matrix Column 2 Inputs is Inspection Procedure (IP) 95001 Supplemental Inspection Response to Action Matrix Column 2 Inputs. Inspection Manual Chapter (IMC) 2515 App. B Supplemental Inspection Program, is the principle resource for supplemental inspection-related governance applicable to multiple supplemental IPs. Both of these documents were recently revised.

IP 95001 content applicable to multiple supplemental IPs was relocated to IMC 2515B. Content explicitly related to extent-of-condition and extent-of-cause was fundamentally unchanged. As briefed the October 2020 ROP presentation (ADAMS Accession No. ML20295A347), supplemental inspection program enhancements were incorporated to promote more effective, transparent, objective, predictable, and scrutable supplemental inspection, assessment, communications, documentation, and follow-up inspection.

The enhancements largely apply to the full scope of the supplemental inspection process - not just to extent-of-condition and extent-of-cause inspection, assessment, and documentation. A few of these broad enhancements (ADAMS Accession No. ML20295A347):

a) 2515B-04 Definitions - Acknowledges that licensee language may differ from definitions used in the program and focuses inspection on the effectiveness of licensee analyses, documentation, and actions to preclude repetition of significant

(i.e. greater-than-green) licensee performance issues whether reflected by findings or performance indicators - not nomenclature.

b) 2515B-07 Enhanced Inspection, Assessment, and Successful Completion -

Emphasizes the enhanced level of inspection, assessment, and documentation necessary in supplemental inspection in comparison to other inspection activities -

regardless of whether an issue is being closed or held open. Reinforces and fully aligns governance with approved ROP bases applicable to supplemental inspection (including extent-of-condition and extent-of-cause inspection, assessment, and documentation).

c) 2515B-08 Initiating, Delaying, Suspending, or Expanding Supplemental Inspection -

Addresses past issues in these areas and reinforces the importance of prompt, effective inspector communication with licensee and NRC management prior to suspending or expanding a supplemental inspection (including issues associated with extent-of-condition, extent-of-cause).

d) 2515B-09 Findings, Violations, General-and Significant Weaknesses - More clearly differentiates minor, general, and significant weaknesses and associated NRC actions (including weaknesses associated with extent-of-condition, extent-of-cause) in relation to findings and violations.

e) IMC 2515B-10 Inspector Requirements, Reactor Oversight Process (ROP)

Expectations, and Regulatory Obligations - More clearly differentiates inspector requirements, ROP expectations, and regulatory obligations in the context of weaknesses identified during supplemental inspection (including weaknesses associated with extent-of-condition, extent-of-cause).

f) IMC 2515B-11 Follow-up Inspection of Planned Corrective Actions - Facilitates measures to ensure follow-up inspection of acceptably-planned but incomplete or uninspected corrective actions to preclude repetition of GTG performance issues (including those associated with extent-of-condition, extent-of-cause).

Question 2: Are there plans to provide additional clarity to NRC inspectors through internal training/documents that would minimize confusion on what is the correct scope for those reviews.

NRC Response 2: The NRC plans to provide additional clarity associated with supplemental inspection process enhancements to NRC inspectors and managers through internal training and enhanced governance documents. The training is not specific to the scope of extent-of-condition and extent-of-cause reviews but will not explicitly exclude those topics.

Communicating with the NRC staff At the start of all ROP public meetings, the project manager provides contact information for the public to use to provide their name as a participant in the meeting. This contact information is also provided for submitting questions and comments to the NRC technical staff. Please note that any questions and/or comments pertaining to the ROP project can be sent to Tekia.Govan@nrc.gov. Questions and/or comments will be forward to the appropriate NRC staff. The staff also mentioned the role out of the Contact Us about ROP page on the new

ROP website, which can also be used to submit questions and comments regarding the ROP initiative (https://www.nrc.gov/reactors/operating/oversight/contactus.html).

Conclusion At the end of the meeting, NRC and industry management gave closing remarks. NEI expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC management stressed the importance of NRC being focused on providing reasonable assurance of public health and safety when considering changes to the ROP.

The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML20322A191

• via email OFFICE NRR/DRO/IRAB/PM NRR/DRO/IRSB NRR/DRO/IRAB/BC NRR/DRO/IRAB/PM NAME TGovan*

BCurran*

AMasters*

TGovan*

DATE 11/16/2020 11/16/2020 11/17/2020 11/17/2020

Enclosure LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS MONTHLY PUBLIC MEETING October 28, 2020, 9:00 AM to 12:30 PM Name Organization1 Name Organization Justin Wearne NEI Alex Garmoe NRC Ken Heffner Certrec Rob Krsek NRC Jim Slider NEI David Aird NRC Shannon Rafferty-Czincila Exelon Alonzo Richardson NRC Tim Schenk River Bend Station Heather Jones NRC Jonathan Johnson TVA Robert Kahler NRC Robin Ritzman Curtiss Wright Julio Lara NRC Steve Catron NextEra Jeffrey Bream NRC Stephanie Pyle Entergy Tekia Govan NRC Joe Cole SNC Licensing Douglas Bollock NRC John Giddens Entergy Jason Drake NRC Tony Zimmerman Duke Energy Christopher Cauffman NRC Kevin McCarthy Entergy Phil McKenna NRC Carlos Sisco Winston Strawn LLC Anthony Masters NRC John Fralick Entergy Steven Campbell NRC Enrique Melendez-Asensio Consejo de Seguridad Nuclear Russ Cassara NRC Melanie Brown Southern Nuclear Charles Murray NRC Rob Burg EPM Eric Bowman NRC Lori Tkaczyk Unknown Kent Chambliss NRC Larry Nicholson Certrec Eric Duncan NRC Tom Basso Unknown Matthew Leech NRC David Mannai Unknown Raymond Gibson NRC Paul Bradley Unknown Russell Gibbs NRC Linda Dewhirst Unknown Jasmine Gilliam NRC Gregory Ferrigno Unknown Jeremy Groom NRC Steven Dolley S&P Global Platts Maria Groshner NRC Martin Phalen Unknown David Garmon-Candelaria NRC Nicole Good STARS Alliance Joylynn Quinones-Navarro NRC Chris Earls Unknown Ravi Grover NRC Steve Geier NEI Andy Rosebrook NRC Edwin Lyman Union of Concerned Scientist Emma Haywood NRC Shane Gatter Unknown Michael Webb NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Name Organization Name Organization Cheryl Ann Gayheart Unknown Sherlyn Haney NRC Jonathan Hartman Unknown Shakur Walker NRC Lisa Hogg Unknown Thomas Hipschman NRC Jerry Humphreys Unknown Tara Inverso NRC Matthew Euten Unknown Marc Ferdas NRC Pamela Frazier Unknown Ken Kolaczyk NRC Michael Kennard Unknown John Hughey NRC Brian Kremker Unknown Don Johnson NRC Steven Martin Unknown Russell Felts NRC Helen Levendosky Unknown Harry Freeman NRC Kelli Anne Roberts Unknown Thomas Fredette NRC Rebeca Saiz Unknown Daniel Ju NRC Martin Murphy Xcel Energy Michelle Kichline NRC Kari Osborne Unknown Lisa Regner NRC Jennifer Varnedoe Unknown Jason Kozal NRC Jeffrey Vollmer Unknown Julio Lara NRC Tim Riti NEI Aron Lewin NRC Jean Fleming PSEG Rebecca Sigmon NRC David Young NEI Greg Suber NRC Ross Telson NRC Eric Thomas NRC Mike Montecalvo NRC Jeff Mitman NRC Chris Miller NRC Hironori Peterson NRC Laura Kozak NRC Rayo Kumana NRC John Lane NRC Mike McCoppin NRC Eric Magnuson NRC Chris Swisher NRC Chris Speer NRC Muzammil Siddiqui NRC Stephanie Morrow NRC Ching Ng NRC Ty Ospino NRC Brain Parks NRC Derek Widmayer NRC Raymond Trelka NRC Daniel Turpin NRC Dave Werkheiser NRC Jimi Yerokun NRC Matt Young NRC