ML21348A754
| ML21348A754 | |
| Person / Time | |
|---|---|
| Issue date: | 12/14/2021 |
| From: | Tekia Govan NRC/NRR/DRO |
| To: | Masters A NRC/NRR/DRO/IRAB |
| Govan T | |
| References | |
| Download: ML21348A754 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 14, 2021 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
SUBJECT:
SUMMARY
OF THE REACTOR OVERSIGHT PROCESS MONTHLY PUBLIC MEETING HELD ON DECEMBER 2, 2021 On December 2, 2021, 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 various ROP initiatives. The topics discussed during this teleconference are described below.
Feedback from External Stakeholders Regarding NRCs Transformation Efforts (Survey)
The NRC staff provided an overview of the External Stakeholder Feedback Survey on Transformation (Agencywide Document Access Management System (ADAMS) Accession No.ML21326A178). The purpose of the presentation was to provide participants with high level details regarding the survey, explain how the staff intends to use survey feedback, and encourage meeting participants to take the survey. The staff received no questions from meeting participants, and industry representatives indicated that that they would provide the survey link to their organizations and encourage participation.
Problem Identification and Resolution Updates The NRC staff discussed the status of upcoming changes to the Problem Identification and Resolution Inspection Procedure, IP 71152, Biennial Inspection. As the result of a comprehensive review, the staff will move the accounting for the daily corrective action program review to Inspection Manual Chapter 2515 Appendix D, Plant Status. Clarifications will be added for inspection staff performing the Safety Conscious Work Environment evaluations. Longer term recommendations will be made prior to the inspection cycle that CONTACT: Tekia V. Govan, NRR/DRO 301-415-6197
begins in 2024. A new SECY Paper will be submitted to the Commission in 2022 providing recommendations for keeping the team inspections as biennial or changing the frequency to triennial.
NRC staff response to NEI White Paper, Proposal to Replace the ANS-PI with an ERFER-PI The NRC staff provided an update on the review of the NEI White Paper, Proposal to Replace the ANS-PI with an ERFER-PI. The staff is continuing its review of this White Paper and will provide it back to NEI, for discussion, at a future ROP public meeting. That staff indicated that their review has not yet yielded comments that would be considered substantial.
Selection of Commercial Grade Dedication as the Next Focused Engineering Inspection The NRC staff shared the selection of Commercial Grade Dedication (CGD) as the next focused engineering inspection program area to replace the power-operated valve inspections beginning in January 2023 (ADAMS Accession No. ML21323A049). The staff discussed the plan to develop and implement the new CGD inspection procedure and to provide training to NRC inspection staff. The staff expects the publicly available draft of the procedure to be available in Spring 2022. The staff also indicated that the new CGD training that NRC staff receives will be made publicly available in the near future and the NRC will plan future public meetings to further discuss CGD inspection implementation prior to the first inspections. The staff indicated that they plan to: 1) utilize the lessons learned from both Environmental Qualification and Power-Operated Valve inspections in development of the CGD inspections, 2) develop training and implementation guidance for the CGD inspections, including designated technical and programmatic leads for the CGD inspections, and 3) conduct cross-regional review panels following CGD inspection completion at each site.
Fire Protection Inspection Enhancements NEI presented on the attributes of the Fire Protection Team Inspection (FPTI) and indicated that the FPTI are redundant to attributes of other NRC inspections (ADAMS Accession No. ML21334A356). NEI stated that the low numbers of FPTI findings indicates strong industry performance and recommended that the NRC staff incorporate unique FPTI inspection criteria to Comprehensive Engineering Team Inspection (CETI) and credit other Inspection Procedures (IPs), as applicable.
NRC Staff Response: The staff will review NEIs presentation material and be prepared to discuss this topic at a future public meeting.
Greater-Than-Green Performance Indicator ROP Recommendation Discussion NEI provided a presentation with reasons for not supporting the staff recommendation in SECY-19-0067 to revise the treatment of greater-than-Green Performance Indicators (PIs) so that they remain Action Matrix inputs until satisfactorily completing the appropriate supplemental inspection (ADAMS Accession No. ML21335A260). NEI stated that the staff used a limited
number of data points for the time it takes for licensees to notify the NRC of their readiness for the supplemental inspection from 2016-2019 to justify the change.
NRC Staff Response: The staff pointed out that there was a significant change to the ROP in 2016 that changed the criterion to move to Column 3 of the Action Matrix from two to three White inputs may have been a factor that contributed to the steep increase in time to prepare for the inspection. Prior to 2016, licensees were highly motivated to complete the supplemental inspection for a White PI while in Column 2 to regain margin to avoid moving to Column 3 in the event of another White input. After 2016, licensees had less incentive to complete the supplemental inspection as quickly as possible because there was greater margin before potentially moving to Column 3.
NEI stated that the proposed change amounts to an increase in regulatory burden that was not justified while there was no challenge to reasonable assurance of adequate protection of public health and safety.
NRC Staff Response: The staff stated that they did not agree with the assertion that the revised treatment of PIs was an increase in regulatory burden because the regulatory response in either case was the same, a supplemental inspection. The staff position is that safety is increased when licensees identify the causes behind declining performance as evidenced by a PI crossing a safety significant threshold and implement corrective actions as soon as possible.
NEI also stated that when the ROP was developed, PIs and inspection findings were not supposed to be treated the same because PIs represented real time licensee performance.
NRC Staff Response: The staff referred to SECY-99-007, Recommendations for Reactor Oversight Process Improvements, (ADAMS Accession No. ML992740074) which stated, crossing PI or cornerstone inspection area thresholds will have similar meaning and will result in the NRC considering a similar range of actions.
NEI expressed a concern that the recommendation would be applied broadly to address some timeliness concerns from outliers who took up to nine quarters to complete supplemental inspections for White PIs, which staff concluded was not commensurate with the safety significance of the issues. Industry suggested that NRC should utilize existing regulatory tools to address those individual behaviors.
NRC Staff Response: The staff stated they werent sure what regulatory tools were available to compel licensees to prepare for supplemental inspections more quickly, and that it would not be a good use of licensee and regulator time to inspect a licensees causal analysis and corrective actions before the licensee notified the NRC of its readiness.
NEI provided several reasons why timeliness for preparation of supplemental inspections were challenging, including the use of the PI frequently Asked Question (FAQ) process. The FAQ process is used by licensees when there are interpretation questions as to whether something is reportable against a PI. This process can take several quarters to resolve.
NRC Staff Response: The staff stated that licensees should not wait on the results of an FAQ before conducting causal analyses and identifying corrective actions because the PI may still cross the significance threshold if the FAQ is not accepted.
Industry stated that licensees do not wait for the FAQ results before preparing for a potential supplemental inspection.
Follow-on COVID Lessons Learned Charter Update The NRC staff provided an update that the working group charter was approved for the follow-on review of the challenges, lessons learned, and best practices during the COVID-19 lessons learned working group charter was approved health emergency. The internal team has since held its first meeting. The staff plans to hold several public meetings to share best practices and lessons learned for inspection and oversight during the pandemic. The charter for this effort can be found in ADAMD under accession number ML21322A259.
Insight from Temporary Instruction (TI) -194 Implementation The NRC staff presented insights from the implementation of Temporary Instruction (TI) 2515-194, Inspection Of The Licensees Implementation Of Industry Initiative Associated With The Open Phase Condition Design Vulnerabilities In Electric Power Systems (NRC Bulletin 2012-01), and the status of the Open Phase Condition (OPC) Bulletin Closeout (ADAMS Accession No. ML21321A356). The staff also discussed observations related to the review of changes to address OPC and their potential inclusion into licensee site-specific probabilistic risk assessments (PRA). More specifically, the expectation that licensees would review those changes to determine if those changes should be included into their PRA in accordance with established guidance and standards. An industry representative commented that licensees would be expected to follow Regulatory Guide 1.200 Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities and the PRA standards.
Probability Risk Assessment (PRA) Configuration Control As a part of previous public meeting, the NRC staff held a PRA Configuration Control Workshop. During that workshop the NRC staff discussed the oversight gap being addressed with the PRA Acceptability Framework, by developing guidance for a PRA configuration control inspection. During this meeting, the staff briefed the purpose and provided a high-level summary of the topics that will be discussed during the next PRA Configuration Control Workshop scheduled for February 2, 2022, from 1pm - 4pm.
Two comments from industry representatives were received. The first comment indicated that the industry understood the need to comply with the ASME/ANS PRA Standard as it relates to PRA Configuration Controls, but they did not see a gap in the ROP as it pertains to PRA Configuration Controls. The second comment received indicated that it would be unclear how the impact of maintenance changes would be inspected as it relates to PRA Configuration Control. The NRC will ensure that both comments are addressed during the workshop in February.
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. The industry representatives expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC management stressed the importance of the 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
ML21348A754 * = via email OFFICE NRR/DRO/IRAB/PM NRR/DRO/IRAB/BC NRR/DRO/IRAB/PM NAME TGovan*
AMasters*
TGovan*
DATE 12/14/2021 12/14/2021 12/14/2021
Enclosure LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS MONTHLY PUBLIC MEETING December 2, 2021, 9:30 AM to 12:00 PM Name Organization1 Name Organization Nicole Good Star Alliance Micheal Smith NRC Allison Read EPRI James Anderson NRC David Young NEI Robert Krsek NRC Bob Murrell Unknown Don Johnson NRC Juan Flores Unknown Nicole Fields NRC Tony Zimmerman Duke Energy Douglas Bollock NRC Robin Ritzman Curtiss-Wright Lisa Regner NRC Steve Catron NextEra Shakur Walker NRC Alan Campbell NEI Tekia Govan NRC Joe Podles Unknown Caty Nolan NRC Stephenie Pyle Entergy Christopher Regan NRC Zachery Betsill Edwin Hatch Nuclear Generating Plant Ross Telson NRC Tim Riti NEI Jeffrey Bream NRC Carlos Sisco Winston and Strawn Anthony Masters NRC Frances Pimentel NEI Edgardo Torres NRC Richard Nichols Unknown Vijay Goel NRC Al Lafleur NextEra Energy Anthony Smallwood NRC Faramarz Pournia Unknown Daniel Merzke NRC Edwin Lyman Union of Concern Scientists Jennifer Whitman NRC Ron Gaston Entergy Charles Murray NRC Deann Raleigh Unknown Avinash Jaigobind NRC David Mannai PSEG David Aird NRC Andrew Mauer NEI Asley Demeter NRC David Gudger Exelon Nuclear Sunil Weerakkody NRC Gary DeMoss PSEG Mike King NRC Ryan Blake Unknown Nick Melly NRC Wayne Johnson Unknown Jo Bridge NRC Scott Clausen Unknown Alex Garmoe NRC Andrew Zach EPW Eric Duncan NRC Ryan Treadway Unknown Tony Nakanishi NRC Paul Gunter Unknown Justin Hawkins NRC Jake Strasser Unknown Khoi Nguyen NRC Jimmy Chang Unknown Naeem Iqbal NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
Name Organization Name Organization Johnathan Thomas Unknown John Hughey NRC Rob Burg EPM Jason Reed NRC Cheryl Ann Gayheart Southern Company Thomas Hipschman NRC Tracy St Clair Unknown Kenneth Kolaczyk NRC Thomas Forland Cooper Nuclear Station Duane White NRC Ertman Bennett III Unknown Melissa Chui NRC Russell Thompson TVA Kari Osborne NRC Tom Byrne Unknown Doris Lewis NRC Tamatha Womack Unknown Catherine Kanatas NRC Bob Hirmanpour Unknown Brigit Larsen NRC Matthew Dickerson Nebraska Public Power District Wendell Morton NRC Charlene Chotalal North Anna Power Station Reinaldo Rodriguez NRC Melody Rodriguez Unknown Antonios Zoulis NRC Robert Rishell Unknown Eugene Dipaolo NRC Victoria Anderson Unknown Stephen Campbell NRC Mandy Halter Entergy Jared Justice NRC Stephenie Pyle Entergy James Drake NRC Andy Barker TVA Glenn Dentel NRC Valerie Gray NRC Johnathan Fiske NRC Sam Graves NRC Frances Ramirez NRC Ching Ng NRC Amy Hardin NRC Kevin Campbell NRC Mike Ordoyne NRC Micheal Montecalvo NRC