ML22286A238
| ML22286A238 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/2022 |
| From: | Kenneth Kolaczyk NRC/NRR/DRO/IRAB |
| To: | Philip Mckenna NRC/NRR/DRO |
| Kenneth Kolaczyk, NRR/DRO/IRAB, 7738917 | |
| References | |
| Download: ML22286A238 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 20, 2022 MEMORANDUM TO: Philip J. McKenna, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Signed by Kolaczyk FROM: Kenneth Kolaczyk, Reactor Operations Engineer on 10/20/22 Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE REACTOR OVERSIGHT PROCESS BI-MONTHLY PUBLIC MEETING HELD ON SEPTEMBER 28, 2022 On September 28, 2022, 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 representatives to discuss the staffs progress on initiatives related to the ROP and discussions regarding Frequency Asked Questions submitted to the NRC staff for consideration as part of the NRC Performance Indicator Program. The topics discussed during this meeting are described below.
Significance Determination Process (SDP)Timeliness Review The NRC staff provided an update to an ongoing review of timeliness associated with potentially greater-than-Green findings in the SDP. The purpose of the review is to identify any common themes or trends associated with findings that exceeded the 255-day metric as defined in IMC 0307, Appendix A. Staff presented a list of nine ideas to improve metric and/or program guidance. Additional outreach is planned. Any recommendations related to changes to the metric or SDP guidance will be further reviewed and approved by NRC management. A summary of the review along with final recommendations will be documented in a publicly available report by the end of calendar year 2022.
Industry representatives provided several comments and questions during the meeting related to this review.
Industry comment: Upfront time performing work in support of a root cause analysis (e.g.,
component tests or failure modes and effects analyses) is important to help determine if there is a licensee performance deficiency.
CONTACT: Kenneth Kolaczyk, NRR/DRO (585) 773-8917
P. McKenna NRC staff response: The SDP affords licensees an opportunity to provide available information that may be useful to the staff in arriving at a best-informed decision within a reasonable time.
Early communication between the licensee and the NRC regarding information that may be pertinent to the NRC staff determination of a performance deficiency should continue to occur.
Consistent with existing guidance, the NRC staff will consider information presented later in the process (e.g., at a Regulatory Conference) that may influence the performance deficiency description if that information was not available during the development of the original performance deficiency.
Industry comment: Interactions between the licensee and NRC staff (e.g., NRC senior reactor analysts) are important and should occur early in the process.
NRC staff response: We agree, and our understanding and experience is that those conversations are happening early and often. Dialogue and information sharing supports the fundamental SDP attribute of transparency, and the NRCs Principles of Good Regulation.
Communication between licensee staff and NRC staff is encouraged at all stages of the SDP.
Industry comment: NRC should take the time necessary to get to the right answer.
NRC staff response: Maintaining public credibility requires timely public notification of the existence of a potentially significant finding. To make effective decisions, appropriate consideration of uncertainty needs to be applied at all stages of the process. Ultimately, consensus regarding the final significance determination of a licensee performance deficiency is the responsibility of the Significance and Enforcement Review Panel.
Industry comment: Did the scope of the timeliness review analyze if there was a decision to exceed the metric and was that decision appropriate?
NRC staff response: No. For the potentially greater-than-Green findings studied as part of this review, the primary contributing cause was identified. Since the SDP timeliness metric measures the time from identification of a potential issue until final significance determination, it is not always evident until later in the process that the timeliness goal will be exceeded.
Industry comment: During the review, did the team members assess the final significance determination of each finding and concur with the result?
NRC staff response: This was not considered or scoped into the timeliness review. As part of the annual ROP self-assessment process, a similar review is conducted for greater-than-Green findings issued during the previous calendar year. The goal is to ensure reliable and predictable program implementation. See the description of Reliability and Performance Metric R-1, Predictability and Repeatability of Significance Determination Results, in IMC 0307, Appendix A, Reactor Oversight Process Self-Assessment Metrics and Data Trending.
Industry comment: With fewer greater-than-Green and potentially greater-than-Green findings in the past several years, did the review team assess whether the uniqueness of these findings contributed to them taking longer to finalize?
P. McKenna NRC staff response: All findings are subject to the same timeliness goals regardless of the SDP appendix used to determine the safety or security significance. Some findings may be more complex than others and the staff strives to recognize those findings early. For example, when inspection findings do not initially screen to Green using the various SDP screening tools an Inspection Finding Review Board (IFRB) is typically convened. One of the objectives of the IFRB is to ensure there is early alignment on the scope, schedule and involved resources to support an efficient and effective preliminary significance assessment. A recently issued greater-than-Green security issue at Davis-Besse in NRC inspection report 05000346/2021405 was assessed by the review team. This was the first finalized greater-than-Green issue related to cyber security, and this first-of-its-kind nature may have partly contributed to missing the 255-day timeliness metric.
Presentation: Significance Determination Process Timeliness Review - (ML22269A480)
Status of ROP Enhancement Activities The NRC staff provided an update of the status of the ROP Enhancement Commission SECY papers schedule (ADAMS Accession No. ML22025A132) that were last discussed in the July ROP Public Meeting. The 4th Quarter Performance Indicator (PI) Treatment and Greater-Than-Green PI Treatment SECY paper (SECY-22-0086) (ADAMS Accession No. ML22188A221) was submitted to the Commission on September 16, 2022. The Problem Identification and Resolution (PI&R) SECY paper (SECY-22-0087) (ADAMS Accession No. ML22252A161) was provided to the Commission on September 20, 2022. The White/Yellow Findings Definitions revision in Inspection Manual Chapter (IMC) 0609 is ready to be issued but will wait until a corresponding change to the Enforcement Policy is sent to the Commission in a SECY paper at the same time. This activity is projected to occur in about one to two months. The Emergency Planning (EP) Significance Determination Process (SDP) revision SECY (SECY-22-0089)
(ADAMS Accession No. ML22189A201) was provided to the Commission on September 22, 2022. The EP Siren Performance Indicator Elimination SECY has been drafted and is projected to be issued in by the end of this calendar year.
COVID Lessons-Learned Status Update The NRC staff provided a status update of the conclusions and recommendations report developed by a working group tasked to review lessons learned, best practices, and challenges during the COVID-19 Public Health Emergency. The staff reported that the recommendations have been reviewed by the Division of Reactor Oversight and forwarded to the Office of Nuclear Reactor Regulation, for consideration.
Overview of Engineering Inspection Initiatives The NRC staff shared that the first 4-year engineering inspection program will begin in January 2023. The 4-year inspection cycle will include IP 71111.21M, Comprehensive Engineering Team Inspection (CETI), which combines the current IP 71111.21M, Design Bases Assurance Inspection (Team), with the triennial portions of IP 711111.07 Heat Exchanger/Sink Performance, and IP 71111.17T Evaluations of Changes, Tests and Experiments, and the three Focused Engineering Inspections (FEIs): IP 71111.21N.05 Fire Protection Team Inspection, IP 71111.21N.03 Commercial Grade Dedication, and IP 71111.21N.04 Age-Related Degradation. The staff stated that IP 71111.21N.04 inspections will not begin until July 2023, and that the final inspection procedure will be completed and publicly available in December 2022. Staff also shared the draft objectives for 71111.21N.04. In addition, staff noted that first public meeting with industry to further discuss CGD inspection implementation was conducted on September 20, 2022. Staff responded to questions from the industry and listened to concerns regarding industry corporate shared resources in supporting simultaneous
P. McKenna inspections in multiple regions. NRC staff reemphasized that inspections will be conducted at each operating reactor licensee site.
Presentation: Overview of Engineering Inspection Activities - (ML22265A176)
Frequently Asked Question (FAQ) 22 Diablo Canyon Scram A representative of the ROP Task Force distributed to the NRC staff a one-page paper that contained recommended or similar wording for the proposed resolution of FAQ 22-02 as described on page 5 of 7 of the FAQ. (ADAMS Accession No.ML22276A240). The NRC staff included the revised wording in the final write-up of the NRCs response to the FAQ. This FAQ has been closed.
FAQ 22 Diablo Canyon Scram - Final Approved - (ML22278A296)
FAQ 22 Susquehanna Scram Proposed Response The NRC staff presented its preliminary conclusion regarding FAQ 22-03 related to an October 11, 2021, Susquehanna reactor plant scram. The guidance needing interpretation was Figure 2, IE04 Unplanned Scrams with Complication - Flowchart, on page 29 of NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, specifically establishing pressure control following the initial transient. After reviewing FAQ 22-03, the NRC staff concluded that the question "Was pressure control unable to be established following the initial transient?" should be answered "No." Following the initial transient, despite an EHC failure, pressure control was able to be established using the Main Steam Line Drains and the High-Pressure Coolant Injection (HPCI) in pressure mode as part of the pressure control system.
Pressure was established without the automatic cycling of SRV(s) and without having failed open SRV(s). Therefore, this event should not be classified as an Unplanned Scram with Complications.
During the meeting, the NRC staff provided the following as background information for the topic:
FAQ 22 Susquehanna Scram Proposed Response - (ADAMS Accession No. ML22278A766)
The FAQ was finalized and approved at the meeting:
FAQ 22 Susquehanna Scram - Final Approved - (ML22278A766)
PRA Configuration Control Review Update The NRC staff discussed preliminary results of three of eight PRA Configuration Control tabletops along with an update to the overall plan and path forward to the agencys framework, addressing the PRA Configuration Control oversight gap.
Presentation: PRA Configuration Control Review - (ML22263A477)
The Next ROP Meeting:
The next ROP bi-monthly public meeting is tentatively scheduled as a hybrid meeting (NRC Commissioner Meeting Room and MS Teams) for Thursday, November 17, 2022.
P. McKenna Communicating With The NRC Staff At the start of all ROP public meetings, the meeting organizer provided contact information for the participants to use to provide their name as a participant in the meeting. This contact information was also provided for submitting questions and comments to the NRC technical staff. Please note that any questions and/or comments pertaining to the ROP can be sent to Kenneth.Kolaczyk@nrc.gov. Questions and/or comments will be forward to the appropriate NRC staff.
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
ML22286A238 NRR-106 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME KKolaczyk* PMcKenna* KKolaczyk*
DATE 10/18/2022 10/19/2022 10/20/2022 LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BI-MONTHLY PUBLIC MEETING September 28, 2022, 9:30 AM to 12:00 PM Name Organization1 Name Organization James Morris PG&E David Aird NRC Steve Catron NextEra Philip McKenna NRC Bob Murrell NextEra Meena Khanna NRC James Slider NEI James Drake NRC Tim Riti NEI Jonathan Fiske NRC Tony Brown NEI Zachary Hollcraft NRC Larry Nicholson Certrec Marc Ferdas NRC Nicole Good Stars Alliance Ty Ospino NRC David Mannai PSE&G Kenneth Kolaczyk NRC Melody Rodriguez NEI Antonios Zoulis NRC Carol Seipp Xcel Ray Azua NRC Roy Linthicum Constellation Energy Ashly Demeter NRC Martin Murphy Xcel Don Johnson NRC Andrew Mauer NEI Ronald Cureton NRC James Orr Constellation Nuclear Laura Kozak NRC Stuart Loveridge Rymer TVA Julie Winslow NRC Naeem Iqbal NRC Avinash Jaigobind NRC Kenneth Mack NextEra Amy Hardin NRC Michael Richardson PG&E Matthew Humberstone NRC Jack Hicks Luminant Natasha Green NRC Linda Dewhirst NPPD Jennifer Cheung NRC Charles Murry NRC Hang Vu NRC Tony Zimmerman Duke Energy Julio Lara NRC Alison Rivera NRC Brian Benny NRC Charlene N Chotalal Dominion Andy Rosebrook NRC Ramakrishna Thatipamala PG&E Doug Bollock NRC Russell Thompson TVA Daniel Merzke NRC Stephanie Pyle Entergy Lundy Pressley NRC William Schaup NRC Laura Pearson NRC Chris Miller NRC Jen Whitman NRC Ayesha Athar NEI Charles Murray NRC Toni Nakanishi NRC Edgardo Torres NRC Victoria Anderson NEI Brian Hughes NRC Robin Riztman Curtis Wright John Hughey NRC Ken Heffner Unknown 1 Dariusz Szwarc NRC Melody Rodriguez NEI Deann Raleigh NEI Keri Osborne Southern Ekaterina Lenning NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
Enclosure
Name Organization1 Name Organization Jonathan Thomas Duke Alex Garmoe NRC David Garmon NRC Laura Peterson NRC Katie Brown Talen Energy Thomas Dashiell NRC Scott Burnell NRC David Hills NRC Robert Krsek NRC Mathew Leech NRC David Curtis NRC Shawn Lichvar NRC Shakur Walker NRC Lou McKown NRC Richard Stadtlander Xcel Eric Bowman NRC Dante Johnson NRC Jennie Rankin NRC Jonathan Grieves NRC Sara Scott Xcel Nicolas Taylor NRC Patricia Vossmar NRC John Lane NRC Darlene Delk TVA