ML22301A166

Presentation 4 - Recent Biennial PI&R Team Inspection Insights

ML22301A166
Person / Time
Site:	Saint Lucie, Robinson
Issue date:	09/29/2022
From:	Jacob Dolecki, Jeffrey Hamman, Kenneth Kolaczyk NRC/RGN-I/DORS, NRC/RGN-II/DRP/RPB3, NRC/NRR/DRO/IRAB
To:
References
Download: ML22301A166 (8)

Text

Recent Jeff Hamman - 2022 St. Lucie PI&R team lead Biennial PI&R Team Jake Dolecki - 2022 Robinson PI&R team lead Inspection Insights

Topics:

Recent

• Observations from St. Lucie Biennial PI&R

• Observations from Robinson Team

• CAP 2.0/NEI 16-07 Inspection

• All CAPs are not created equal Insights

• Learnings and path-forward

• A more familiar type of PI&R in that the CAP is the point of entry for issues.

• CAP entry threshold was appropriate.

• Two items of interest came out of the inspection: 1) Screening of corporate generated condition reports and 2) Entry St Lucie PI&R method for anonymous concerns.

• Corporate (Juno Beach) CRs were identified by Originating Organization as JB for Juno Beach. One had the Originating Organization as JB and Affected Organization also as JB but applied to Turkey Point.

• The inspectors then questioned if CRs from corporate were screened for operability at the affected site. After some research, FPL respond to the inspectors that corporate CRs go to St Lucie for screening.

• During interviews, the inspectors noted that only one employee of all those interviewed St Lucie PI&R knew the correct method for entering anonymous concerns. All knew about the employee concerns program. However, those who did no know stated that they would not likely have to use anonymous means since they felt comfortable bringing concerns up with their management.

Approach to CAP (NEI 16-07)

• Approved Process: Undesired Condition ->

Work Requests (WR) or Nuclear Condition Report (NCR)

• Minimal CRs (~60-70/month)

Robinson

• CAP or non-CAP (no CARC)

PI&R

• Threshold for condition adverse to quality (CAQ)

• Based on examples, subjective

• Higher threshold -> minimal CAQs

• What is adverse?

• Aiming for investigation and analysis to be commensurate to problem

WR Work Management System (WMS)

Work Request (WR) or NCR Undesired Condition Nuclear Condition Report NCR CAQ or non-CAQ CAP Non-CAP/PI

Results and takeaways

• Plenty of discussion regarding CAQ vs. non-CAQ Robinson

• Enhancements to CAP procedures/examples PI&R

• Less visibility -> more burden on inspectors to identify issues (review WMS and CAP)

• Degraded equipment trending

• Reliance on tribal knowledge

• Compliance with regulations still required (e.g., Criterion XVI)

• Data and information may be decentralized

• Ask questions -- What programs exist for Inspector identifying issues? Standard RFI may not be enough Best

• Does a procedure exist?

Practices

• Review corporate-generated CRs

• Potential for enhancement to IP 71152?