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 Division of Operating Reactors, NRC/RGN-II/DRP/RPB3, NRC/NRR/DRO/IRAB
To:
References
Download: ML22301A166 (8)

Text

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

Recent Biennial PI&R Team Inspection Insights Topics:

• Observations from St. Lucie

• Observations from Robinson

• CAP 2.0/NEI 16-07

• All CAPs are not created equal

• Learnings and path-forward

St Lucie PI&R

• 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 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.

St Lucie PI&R

• 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 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.

Robinson PI&R Approach to CAP (NEI 16-07)

• Approved Process: Undesired Condition ->

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

• Minimal CRs (~60-70/month)

• CAP or non-CAP (no CARC)

• 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

NCR Undesired Condition Work Request (WR) or Nuclear Condition Report Work Management System (WMS)

CAQ or non-CAQ WR CAP Non-CAP/PI NCR

Robinson PI&R Results and takeaways

• Plenty of discussion regarding CAQ vs. non-CAQ

• Enhancements to CAP procedures/examples

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

• Degraded equipment trending

• Reliance on tribal knowledge

Inspector Best Practices

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

• Data and information may be decentralized

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

• Does a procedure exist?

• Review corporate-generated CRs

• Potential for enhancement to IP 71152?