ML21335A260

ROP Public Meeting Gtg PI 12022021

ML21335A260
Person / Time
Site:	Nuclear Energy Institute
Issue date:	12/02/2021
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Govan T
References
Download: ML21335A260 (9)

Text

Feedback on Treatment of Greater than Green Performance Indicators

December 2, 2021

©2021 Nuclear Energy Institute Summary

At the Oct. 20th public meeting, the staff shared that updated data on licensees moving to Column 2 was being considered to inform the original SECY-19-0067 recommendation on treatment of Greater than Green (GTG) Performance Indicators (PI)1

• Revise treatment of GTG PIs to remain Action Matrix inputs until supplemental inspection is completed

• NEIs ROP Task Force reviewed the original recommendation including previous and current licensee data

• We do not recommend moving forward with changes in the treatment of GTG PIs

1 ROP Enhancement SECY 0067 (ML21291A190)

©2021 Nuclear Energy Institute Discussion

There has been a significant reduction in the number of White PIs over the staff s original SECY review period 2006 - 2010 - 33 2011 - 2015 - 23 2016 - 2019 - 5*

• only uses 3 years of data

A very limited data set was used to support the SECY conclusion that readiness for the supplemental inspection for White PIs has increased significantly over the past few years There is limited discussion on factors that may have contributed to increased days to supplemental inspection readiness or on use of the limited data set to support the staff s conclusion The staff noted in ROP public meeting on April 24, 2019, all 2016-2019 White PIs evaluated involved the IE cornerstone

©2021 Nuclear Energy Institute Discussion

Significant changes to the fundamental ROP framework that adds unnecessary regulatory burden2 (e.g., changing the treatment of PIs that cross the Green-White threshold and return to Green prior to the supplemental inspection) should be limited to addressing problems that challenge reasonable assurance of adequate protection of public health and safety PIs are distinct to findings in the ROP framework as they provide metrics/values that are based on safety significance or risk thresholds and provide real time performance feedback Changing the treatment of GTG PIs that return to Green as it relates to the ROP action matrix would disregard the risk-informed, performance-based unique aspects of ROP PIs as they were intended

2 IMC- 0308, Reactor Oversight Process Basis Document

©2021 Nuclear Energy Institute Discussion

It appears that the original recommendation being considered would be applied to the treatment of all GTG PIs based on a limited data set (i.e., 5 examples in the IE cornerstone) without regard to the overall improved PI performance trend It also appears that the original recommendation would be applied broadly to address some timeliness concerns from outliers versus utilizing existing regulatory tools if warranted to address those individual behaviors

©2021 Nuclear Energy Institute Additional Insights

Timeliness to address IE Cornerstone PIs As the staff noted in the April 24, 2019, public meeting, IE cornerstone PIs usually involve discrete events that are individually evaluated when they occur While this may seem like it should streamline supplemental inspection preparations, rarely will the overarching root/common causal evaluation lead to simple broke/fix solutions during the holistic review of multiple occurrences In some cases, root or common causes are difficult to determine and outside vendor/causal evaluation experts are called upon to assist to ensure rigorous evaluations are performed, corrective actions are developed, and extent of condition is properly assessed

©2021 Nuclear Energy Institute Additional Insights

Other insights for declaring readiness for IE cornerstone supplemental inspections Additional PI occurrences during the causal evaluation that needs to be factored into root/common cause Reassessment needed due causal evaluation reviews/mock supplemental inspection readiness assessments Open/resolution of FAQs (unique to PIs)

Examples of initial supplemental inspection failures Overpreparations/history of previous supplemental inspection results One recent example of inspection readiness declared within 5 months of a White PI due to a singular event (non-IE cornerstone)

©2021 Nuclear Energy Institute Conclusion

The reduction of GTG PIs is indicative of improved regulatory performance and effectiveness of NRCs oversight utilizing the ROP We fully support enhancements to the ROP that are more risk-informed and performance based We also believe that incentivizing good performance and focusing NRC resources on departures from desired performance will strengthen the ROP We believe that adding unnecessary regulatory burden for the treatment of GTG PIs is inconsistent with the ROP basis document and disregards the unique aspects of ROP PIs with monitoring performance and how they factor into the ROP action matrix as intended 20+ years ago (e.g., GTG - Yes, Green - No)

While there have been some observed differences between supplemental inspection readiness timeliness between GTG findings & GTG PIs (especially IE cornerstone), there doesnt appear to be a clear problem that needs to be addressed through a major change to a fundamental aspect of the ROP framework that increases regulatory burden

©2021 Nuclear Energy Institute Conclusion

• We do not recommend moving forward with changes to the treatment of GTG PIs based on the reasons described

• The NRC has tools to address outlier behaviors if concerns exist in individual licensee performance for timeliness or other aspects of the ROP

• We appreciate the opportunity to share our thoughts and insights to ROP enhancements being considered including the treatment of GTG PIs

• The ROP Task Force is interested in discussing any ROP enhancements as new data is being evaluated and recommendations are being considered

©2021 Nuclear Energy Institute