ML22334A096

Summary of the Reactor Oversight Process Bi-Monthly Public Meeting

ML22334A096
Person / Time
Issue date:	11/30/2022
From:	David Aird NRC/NRR/DRO/IRAB
To:	Philip Mckenna NRC/NRR/DRO/IRAB
References
Download: ML22334A096 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 30, 2022 MEMORANDUM TO: Philip J. McKenna, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: David M. Aird, Reactor Operations Engineer /RA/

Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUMMARY

OF THE REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING HELD ON NOVEMBER 17, 2022 On November 17, 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, other senior industry executives, and various external stakeholders to discuss the staffs progress on initiatives related to the ROP. The topics discussed during this hybrid meeting are described below.

Significance Determination Process Timeliness Review The NRC staff provided an update to an ongoing review of timeliness associated with potentially greater-than-Green findings in the Significance Determination Process (SDP). The purpose of the review was to identify any common themes or trends associated with findings that exceeded the 255-day metric as defined in Inspection Manual Chapter (IMC) 0307, Appendix A, Reactor Oversight Process Self-Assessment Metrics and Data Trending and develop recommendations to improve timeliness. Staff presented a revised list of five recommendations to improve the metric and/or program guidance. These five recommendations 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 memorandum by the end of calendar year 2022.

The NRC received a letter from NEI on November 16, 2022, providing comments on the SDP timeliness review (ADAMS Accession No. ML22321A315). At the meeting, NEI provided a summary of the comments described in the letter. NEI reiterated that throughout the timeline of the SDP, it is important to have open lines of communication and consider new information that may impact the performance deficiency. In their response to Recommendation #1, NEI provided a point of clarification in their letter that certain situations that may require a Planning Significance and Enforcement Review panel may warrant pausing the SDP metric clock.

CONTACT: David M. Aird, NRR/DRO 3012870725

P. McKenna Presentation: Significance Determination Process Timeliness Review - (ML22311A546) https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22311A546 Status of ROP Enhancement Activities The NRC staff also gave an update of the status of the ROP Enhancement Commission SECY papers schedule (ML22025A132) that were last discussed at the September ROP Public Meeting. The Problem Identification and Resolution (PI&R) SECY paper, the 4th Quarter Performance Indicator (PI) Treatment and Greater-Than-Green PI Treatment SECY paper, and the Emergency Planning (EP) SDP revision SECY paper were all issued in September 2022 and were discussed in the September ROP Bimonthly public meeting. The White/Yellow Findings Definitions revision in IMC 0609 is ready to be issued but will wait until a corresponding change to the Enforcement Policy is sent to the Commission by a SECY paper. This SECY paper is expected to be issued in January 2023. The replacement PI for Alert and Notification System and Emergency Response Facility Readiness SECY has been written, is in internal concurrence, and is projected to be issued in December 2022.

ROP Enhancement: Sample Changes from 2019 to 2023 The NRC staff presented a summary of the inspection procedure changes that are being implemented for the 2023 ROP inspection program. The presentation highlighted both the consistencies and differences between the original proposals from the ROP Enhancement SECY190067 (ML19070A036) and Engineering SECY180113 (ML18144A567) compared to the final 2023 ROP inspection program that incorporated most of the original proposals.

Industry comment: With the advent of the new engineering inspection procedures, has the NRC evaluated the impact on efficiency for implementing the procedures that no one has experience with, either on the NRC side or the licensee side.

NRC staff response: NRC has been conducting dedicated training for the inspection staff at each region to minimize the impact of the lack of experience. But the NRC has not considered evaluating the efficiency change from implementing new procedures. NRC will monitor it as the new procedures are implemented.

Presentation: 2023 ROP Enhancement Implementation - ML22308A147 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22308A147 Safety Culture Program Effectiveness Review The NRC staff provided an update to an ongoing effectiveness review of the safety culture program. The purpose of the review is to conduct a holistic review of the safety culture program, identify any gaps, and develop recommendations to NRR management. Staff presented the results of the review and a list of recommendations to improve the safety culture program in the ROP. Additional outreach will be planned for calendar year 2023. Any recommendations related to changes to the treatment of safety culture in the ROP 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, which are listed below:

P. McKenna 1) There was concern expressed about licensee level of effort required if a safety culture survey would become a requirement of Inspection Procedure (IP) 95001,

2) One industry member stated that IP 95001 already reviews safety culture in the licensees causal evaluation of the issue,

3) One industry member stated that the NRC already has enough tools to inspect safety culture,

4) Several industry members agreed with the recommendation of providing the NRC inspectors more training,

5) One industry member stated that licensees have improved their oversight of safety culture with the implementation of safety culture panels.

One member of the public stated that if safety culture issues are documented in an inspection report, then the NRC should be able to follow-up and inspect those issues.

Presentation: 2022 ROP Self-Assessment: Safety Culture Effectiveness Review -

ML22308A138 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22308A138 Draft Regulatory Basis for 10 CFR 50.72 Nonemergency Reporting Requirements Rulemaking The NRC staff provided an update on the Draft Regulatory Basis for 10 CFR 50.72 Nonemergency Reporting Requirements Rulemaking. A Federal Register Notice was published on November 9, 2022 for public comments (87 FR 67571) providing the Draft Regulatory Basis for the rulemaking (ML22108A004). The staff recommended six nonemergency criteria for removal and that additional clarity be provided for two criteria in the guidance document, NUREG1022, Rev. 3, Event Report Guidelines 10 CFR 50.72 and 50.73 (ML13032A220). The 60-day comment period for the document will close on January 9, 2023. The staff plans to hold a public meeting in early December focused on the nonemergency reporting requirements rulemaking to communicate the rulemaking process, describe the recommendations and the reasoning, explain the comment submittal process, and to answer questions.

During the meeting, the NRC staff was questioned whether the updates to NUREG1022 would be on the same timeframe as the rulemaking currently scheduled for completion in February 2026. The NRC staff responded that it plans a short-term update to NUREG1022 on items such as risk-informed reportability guidance, but any changes associated with the rulemaking would be on a longer timeframe. The NRC staff received an objection to the recommendations from Mr. Edwin Lyman, Union of Concerned Scientists, because of the degradation in NRC openness and transparency. He questioned whether public openness was a consideration in the NRC staffs assessments of changes. The NRC staff responded that public openness and transparency was part of its decision-making process, that his concerns are welcome to be submitted through the formal comment process, and that more discussion would occur at the next public meeting, scheduled for December 13, 2022. Positive feedback was received from industry representatives.

Presentation: 10 CFR 50.72 Update - ML22318A233 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22318A233 The Next ROP Meeting The next ROP bimonthly public meeting is tentatively scheduled for January 18, 2023.

P. McKenna 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 David.Aird@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 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

ML22334A096 * = via email OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME DAird PMcKenna* DAird DATE 11/28/2022 11/29/2022 11/30/2022 LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING November 17, 2022, 9:00 AM to 12:00 PM Name Organization1 Name Organization Tim Riti NEI David Aird NRC Tony Brown NEI Phil McKenna NRC Darlene Delk TVA Ami Agrawal NRC Steve Catron NextEra Ashley Demeter NRC Brandon Shultz Constellation Nuclear Russell Felts NRC Russell Thompson TVA Billy Gleaves NRC Jonathan Thomas Duke Energy Brian Benney NRC Edwin Lyman UCS Zachary Hollcraft NRC Robin Ritzman Curtiss-Wright Dan Merzke NRC Larry Nicholson Certrec Alex Garmoe NRC David Gudger Constellation Nuclear Chris Cauffman NRC Stephenie Pyle Entergy David Jones NRC Nicole Good Stars Alliance Kenneth Kolaczyk NRC Rob Burg EPM, Inc. Mike King NRC Melody Rodriguez NEI Reinaldo Rodriguez NRC James Pak Dominion Energy William Rautzen NRC Tony Zimmerman Duke Energy Brian Hughes NRC Marty Murphy Xcel Stephen Campbell NRC Andrew Mauer NEI Jared Justice NRC Charlene Chotalal Dominion Energy Tom Hipschman NRC Deann Raleigh Unknown Ronald Cureton NRC Andrew Zach EPW Avinash Jaigobind NRC Jeffery Stone Constellation Nuclear Lundy Pressley NRC Jeremy Aiello Constellation Nuclear Julie Winslow NRC Matthew Rossi Constellation Nuclear Jeff Bream NRC Roy Linthicum Constellation Nuclear Charity Pantalo NRC James Orr Constellation Nuclear Scott Wilson NRC Eric Kraus Constellation Nuclear Laura Kozak NRC Cecil Fletcher II Duke Energy Paul Laflamme NRC Lori Hayes Unknown Rob Krsek NRC Justin Wearn PSEG Rebecca Sigmon NRC Victoria Dennis TVA Shakur Walker NRC Cheryl Ann Gayheart Southern Company Lisa Regner NRC Linda Dewhirst NPPD John Hughey NRC Melisa Krick Talen Energy Naeem Iqbal NRC Christopher Courtenay Duke Energy Gabe Taylor NRC Richard Stadtlander Xcel Manuel Crespo NRC David Mannai PSEG Jen Whitman NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Enclosure

Name Organization1 Name Organization Carlos Sisco Winston & Strawn Joshua Havertape NRC Charles Murray NRC Nikki Warnek NRC Candace de Messieres NRC Nicole Fields NRC Doug Bollock NRC Joey McPherson NRC Shane Sandal NRC Mario Fernandez NRC Eric Bowman NRC Eric Schrader NRC Paul Rades NRC Chris Speer NRC Stephanie Mercurio NRC Jonathan Fiske NRC Joe Gillespie NRC Marcus Chisolm NRC Atif Shaikh NRC Larry Grimes NRC Zee St Hilaire NRC Jack Vande Polder NRC Maxine Keefe NRC Shawn Lichvar NRC Ty Ospino NRC James Kepley NRC James Mejia NRC 2