ML22349A505
| ML22349A505 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/08/2023 |
| From: | Philip Mckenna NRC/NRR/DRO/IRAB |
| To: | Russell Felts NRC/NRR/DRO |
| References | |
| Download: ML22349A505 (9) | |
Text
R. Felts 1 February 8, 2023 MEMORANDUM TO: Russell Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation Signed by McKenna, Philip FROM: Philip J. McKenna, Chief on 02/08/23 Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
RESULTS OF A REACTOR OVERSIGHT PROCESS SELF-ASSESSMENT EFFECTIVENESS REVIEW OF THE RECOMMENDATIONS FROM IP 95003 AT ARKANSAS NUCLEAR ONE
SUMMARY
This memo presents the results from the calendar year (CY) 2022 Reactor Oversight Process (ROP) self-assessment effectiveness review of the actions taken to address the recommendations from the Arkansas Nuclear One (ANO) Inspection Procedure (IP) 95003 Lessons Learned Report, dated June 8, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17160A290). The staff reviewed the actions associated with each recommendation, including any supporting data, to determine whether the ROP change was effective as implemented, and whether there were any unintended consequences from the change. As a result of the staffs analysis of the ROP program execution data, as well as other insights, the staff concluded that the actions taken to address the recommendations from the ANO 95003 lessons learned report have been effective for those recommendations where action was taken.
BACKGROUND:
In accordance with IMC 2515, Appendix B, Supplemental Inspection Program, and IMC 0305, Operating Reactor Inspection Program, the staff conducts IP 95003, Supplemental Inspection Response to Action Matrix Column 4 (Multiple/Repetitive Degraded Cornerstone Column)
Inputs when a licensee enters Column 4 of the ROP Action Matrix. In Column 4 of the ROP Action Matrix, although the cornerstone objectives of the ROP are still being met, there are either longstanding safety issues or a significant degradation in licensee safety performance.
As such, IP 95003 incorporates an evaluation of NRCs response to declining licensee performance to determine whether the NRC assessment and inspection processes appropriately characterized licensee performance based on previous information and whether sufficient warning was provided to identify a significant reduction in safety.
CONTACT: Ronald Cureton, NRR/DRO (704) 277-4534
R. Felts 2 EFFECTIVENESS REVIEW DATA ANALYSIS APPROACH:
To evaluate the effectiveness of the recommendations from IP 95003 at ANO, the staff reviewed the content of the recommendations; reviewed the documented basis for the recommendations; reviewed the status of the recommendations; reviewed the closure actions and any documentation for all recommendations no longer categorized as open; and reviewed the current path forward for any open recommendations. The staff reviewed the actions to address each recommendation to determine if the change met the intended outcome of the recommendation, determine if the actions were effective through data analysis, where available, determine if there were any unintended consequences associated with the actions, and verify the changes remained consistent with the ROP goals and the Principles of Good Regulation.
DISCUSSION:
The IP 95003 evaluation of NRCs response to declining ANO performance contains a total of 10 recommendations. As of December 12, 2022, five have been closed, one is still open, and four recommendations were not pursued.
The 10 recommendations, the status, and the results of the effectiveness review for each are described below:
ANO Recommendation 1 Recommendation Consider expanding the inspection objectives of IP 71111.20, Refueling and Other Outage Activities, to include evaluating the licensees outage risk recognition and management for planned activities which may have a high potential safety consequence, even if it appears to have a low probability. In particular, activities of interest should include heavy load lifts and other activities which could upset an operating unit, cause loss of power, compressed air or cooling water, cause flooding, or impact fuel transfer or the integrity of radiological barriers even if the activity is not specifically related to safety-related equipment.
Implemented? Yes. Included activities of interest noted by the inspection team to 71111.20 (section 03.01). Revised OpESS 2007-03 rev 2. Added references to 71111.20 - NUREG 0612, GL-8107, OpESS 2007 - 03.
Status Closed Effectiveness Effective. The staff reviewed 30 inspection findings under IP 71111.20 since 2019 and identified 3 findings where the licensee failed to perform an adequate risk assessment, one of which included a heavy lift. Inspector awareness of the issues enhanced by the revision to the IP, led to identification of these findings.
Unintended consequences None identified ANO Recommendation 2 Recommendation Improve inspector knowledge of flood protection design strategies and flood protection features for both internal and external sources. Insights gained at ANO may be useful in developing training or an Operating Experience Smart Sample.
Implemented? Yes. Detailed guidance for inspecting flood protection measures was added to NUREG/BR-0326, Inspector Field
R. Felts 3 Practices. There was also a procedure revision to OpESS 2007-02 as a result of this recommendation. While there was no formal inspector training associated with flood protection design and strategies, the OpESS was presented at inspector counterpart meetings in 2018 to ensure inspectors were aware of the revision. A review of annual end-of-cycle assessment packages found several inspection plans referencing OpESS 02007-02.
Status Closed Effectiveness Effective. Increased inspector awareness of flooding issues.
Of the eight inspection findings associated with IP 71111.06 since the beginning of 2019, five NCVs were identified by inspectors during flood protection walkdowns.
Unintended consequences None identified ANO Recommendation 3 Recommendation Improve the inspection and assessment programs to improve the ability to identify Problem Identification and Resolution (PI&R) programs or individual program elements that may not be adequate to support the assumptions of the ROP. (Recommendation subparts a. through f.)
Implemented? No. Item still open: Considered in PI&R comprehensive review ML20247J602. NRR and Regional management concurred that IP 71152 should be revised to implement Inspection Option 1 and Assessment Option 3. Under Inspection Option 1, the staff would make small modifications to scope and frequency to improve efficiency and effectiveness. In Assessment Option 3, Satisfactory assessment criteria in each of the assessment areas (i.e.,
identification, evaluation, correction of plant problems and SCWE) could be incorporated into the procedure as guidance to utilize for overall licensee PI&R performance assessment. This guidance would provide for a more data-driven qualitative observation of PI&R performance by the inspection lead. Closeout of this action will occur with revision to IP 71152 that is expected to be issued by the end of 2023.
Status Open Effectiveness N/A. Not implemented yet.
Unintended consequences None identified ANO Recommendation 4 Recommendation Revise IP 95001 and IP 95002 to add an inspection objective to independently evaluate the adequacy of programs and processes that may have contributed to the greater-than-Green finding(s) or PI(s), and provide appropriate guidance to help identify the program sample and attributes to be inspected. It is suggested that this review should be analogous to that in IP 95003, but more focused on potential contributing causes for the greater-than-Green finding(s) and PI(s). The results of this review should be factored into whether the licensees corrective actions, extent of cause and extent of condition reviews were adequate to warrant closure of the finding or PI.
R. Felts 4 Implemented? Yes. IP 95001 (Revision dated 10/21/20) and IP 95002 (Revision dated 3/19/21) were both revised to reference IMC 0310 for a review of cross cutting aspects, among other items, to identify if there are any common causes between multiple performance issues.
Status Closed Effectiveness Procedure enhancements were made to IP 95001 and IP 95002 as part of a larger effort to revise supplemental inspection program guidance. Effectiveness has not been evaluated because there have not been enough opportunities to evaluate. An effectiveness review on these revisions will be planned for the future after a sufficient number of IP 95001 and IP 95002 inspections have been completed. This action is being tracked as part of the ROP Self-Assessment Program.
Unintended consequences None identified ANO Recommendation 5 Recommendation Add guidance to IMC 0612, Power Reactor Inspection Reports, to identify that when more than one performance deficiency exists associated with an issue of concern, consideration should be given to selecting a performance deficiency that represents current licensee performance.
Implemented? Yes. Guidance was added to IMC 0612, Appendix B, Issue Screening Directions under Block 2 (Now Block 3 in a further revision of IMC 0612, Appendix B): Is there a performance deficiency? The basis for the recommendation was that a finding representing current licensee performance is more likely to have a cross-cutting aspect assigned. Aggregating cross-cutting aspects would more likely lead to a cross-cutting theme which would be indicative of potential declining performance.
Status Closed Effectiveness Yes. This revision cleared up inspector questions on how to document potential multiple performance deficiencies.
Review of inspection reports since the revision was issued in 2020 demonstrates that inspectors are following this revised guidance. Cross-cutting themes have been identified at some plants, particularly in the area of human performance, directing more NRC attention to these plants.
Unintended consequences None identified ANO Recommendation 6 Recommendation Revise IP 95003 to use the fact-finding approach currently used in IP 93800, Augmented Inspection Team. This approach allows the team to document unresolved items that would be inspected and dispositioned in a separate report. A follow-up inspection should be conducted at a later date to address the specific unresolved items with a team that could be better prepared for detailed reviews.
Implemented? Partially. IP 95003 was revised on 06/07/22 to allow expansion of inspection scope to include all or some of the key attributes of non-degraded Strategic Performance Areas based on weaknesses identified during the inspection effort.
A phased approach to conducting the IP 95003 was already discussed in the 2015 revision to IP 95003 and IMC 0305.
R. Felts 5 The clarified guidance regarding phased inspection satisfies the initial objective to promptly determine if continued facility operation is acceptable. This objective closely aligns with a fact-finding approach; however, the remaining IP 95003 objectives require close and thorough assessment of licensee performance and should not be truncated into a fact-finding format.
The basis for the recommendation was to make the 95003 inspection more efficient by focusing on assessment of licensee performance rather than spending time dispositioning inspection findings. The phased approached allows for issues to be documented as unresolved items that can be resolved by the follow-on IP 95003 efforts.
Status Closed Effectiveness Indeterminate; there have been no subsequent 95003 inspections to use to assess the effectiveness of this action, but all IP 95003 inspections include an assessment of NRC oversight, so the effectiveness of this change will be assessed during the next IP 95003.
Unintended consequences None identified ANO Recommendation 7 Recommendation Develop guidance and training on how to recognize and assign cross-cutting aspects/themes/issues from the 12 safety culture attributes that are currently reserved for use during supplemental inspections (X.1 through X.12). It is recommended that this action include an inspection requirement in IPs 95001, 95002 and 95003 to identify whether there is evidence that the licensee has challenges in supplemental cross-cutting aspects which contributed to the conditions that led to the greater than Green finding(s) or PI(s). If a suitable connection exists, the basis should be documented in the supplemental inspection report and assigned a Cross-Cutting Theme or Cross-Cutting Issue in accordance with guidance in IMC 0305, Operating Reactor Assessment Program. To support this, revise IMC 0305 to include guidance for removing the plant from elevated oversight to include consideration of the licensees progress in addressing these themes or issues.
Implemented? No. It was determined that this change was not needed.
Guidance already exists in IP 95001, 95002, and 95003 to determine if the licensee adequately considered safety culture traits described in IMC 0310 in their causal evaluations. Supplemental cross-cutting aspects X.1 through X.12 are described in IMC 0310 with guidance that they be considered during supplemental inspections.
Status Closed Effectiveness N/A Unintended consequences None identified ANO Recommendation 8 Recommendation Consider revising the IMC 0305 assessment program guidance for plants in Columns 2, 3, and 4 to permit the identification of Cross-Cutting Themes or issues based on supplemental inspection results that indicate a contribution
R. Felts 6 to the finding or PI. The intent of this recommendation is to permit the identification of cross-cutting themes and issues based on their having contributed to greater-than-Green finding(s) or PI(s). Identification of a theme could be used to permit closure of the finding but still causing the licensee to address the theme, while identification of a cross-cutting issue could be used to hold the finding or PI open until the Cross-Cutting Issue was addressed. (Report ML17160A290)
Implemented? No. This recommendation was considered, and it was determined that there should be no change to IMC 0305.
Cross-cutting themes and cross-cutting issues are assigned to communicate to licensees that the NRC has a concern with the licensees performance in a cross-cutting area and to encourage the licensee to take appropriate actions before more significant performance issues emerge. If a licensee is in Column 4, more significant performance issues have already been manifested. A theme indicates there is a unifying concern, meaning there is a pattern that may need to be addressed. A cross-cutting aspect assigned to a greater-than-Green (GTG) finding does not necessarily indicate a pattern, and there is no guidance that cross-cutting aspects assigned to GTG findings should carry additional weight. The recommendation to keep a GTG finding open until a licensee addresses a cross-cutting issue would be a deviation from the Action Matrix. To change the regulatory actions described by the Action Matrix without a deviation would require Commission approval. An annual PI&R sample for follow up could be performed to close out incomplete corrective actions and/or not fully addressed contributors related to the finding. The PI&R biennial inspection requires follow up of corrective actions not accomplished prior to when the original inspection occurred.
Status Closed Effectiveness N/A Unintended consequences None identified ANO Recommendation 9 Recommendation Consideration should be given to creating training on IP 95003, objectives, and methods, as well as how that inspection fits into the Column 4 regulatory oversight strategies. Lessons learned from recent inspections would also be a useful topic. The goal would be to create a cadre of inspectors who are ready to plan, lead and implement a 95003 inspection.
Implemented? No. The frequency of IP 95003 inspections is rare, and even more rare since revising the definition of a degraded cornerstone in 2016. It was determined that the amount of effort that would be required to create this training and to create a cadre of inspectors who were ready to plan and lead a 95003 inspection would not be practical for an inspection that is performed so infrequently. Inspectors who receive the training may leave the inspector program prior to utilizing that training. Lessons learned from previous IP 95003 inspections are readily available to inspectors who are tasked to lead these inspections, and it would be
R. Felts 7 expected that they would review these lessons learned as they prepare for an upcoming 95003 inspection. These effectiveness reviews are available so that inspectors may see how recommendations were dispositioned in the past, and to understand the basis for the decisions to either revise the ROP based on those recommendations, or why a previous recommendation was not implemented.
Status Closed Effectiveness N/A Unintended consequences None identified ANO Recommendation 10 Recommendation Improve plant assessment and supplemental inspection planning as follows (a) Add a row to the ROP Action Matrix to provide specific actions to expand the normal assessment window based on the Action Matrix column for plants outside the Licensee Response Column. It is proposed that when a plant is placed into Column 2, 3 or 4, IMC 0305 should require the regional office to promptly perform an assessment of licensee performance using available information to identify the licensee programs and cross-cutting attributes of concern that may have contributed to the greater than Green finding or PI. The assessment period could be graduated, such that a Column 2 plant might be evaluated using inspection and assessment information for the previous 3 years, and a Column 3 plant might be evaluated for the previous 5 years. Column 4 should determine the period of concern by identifying the probable start of declining performance from all available sources of information. (b) Develop guidance for inclusion in IMC 0305 to describe that potential contributing causes for greater than Green findings and PIs should be developed and used to establish the scope of the supplemental inspection plan and the success criteria to be used. This list should specifically consider the 12 safety culture attributes X.1 through X.12. While the latter attributes may not have been identified during previous assessments, they should be discussed and judgment applied as to whether to investigate their applicability during the supplemental inspection. It is suggested that this list of potential programs and safety culture attributes of concern be promptly communicated to the licensee so that they may appropriately consider those attributes in their safety culture assessment prior to the supplemental inspection. (c) Revise IP 95001 and 95002 guidance to include inspection of each of the programs and safety culture attributes identified as possible contributors to the greater than Green finding(s) and PI(s) through the assessment process described in Recommendation 10.b above.
Implemented? No. During the 2017 Division Director Counterpart Meeting, a consensus was reached that these actions were not necessary. IMC 0305, Section 07.01 already requires the region to perform a continuous review of licensee performance of their assigned plants using the results of inspection findings and PIs. Between the normal quarterly
R. Felts 8 assessments when Performance Indicator data is received from the licensee, the region may issue an assessment follow-up letter and address an issue in accordance with the Action Matrix if a safety-significant inspection finding is finalized (the letter may be combined with the final SDP letter). The safety culture discussion in this recommendation is being addressed in the safety culture effectiveness review which occurred in 2022 as part of the ROP Self-Assessment Program and will be discussed in a separate report.
Implementation of any of the actions from Recommendation 10 would be large programmatic changes that would not be necessary in the current ROP framework that already allows continuous review of licensee performance. In addition, the supplemental inspection procedures contain the necessary guidance to verify that licensees are considering safety culture aspects during their causal analyses for safety-significant inspection findings and performance indicators, which includes the X.1 through X.10 cross-cutting aspects mentioned in the recommendation. The normal assessment window for the annual assessment meeting was expanded to a two-year review of the PIM to determine if there were any trends that may indicate declining performance in an area for potential inspection follow-up.
Status Closed Effectiveness N/A Unintended consequences None identified Conclusion and Recommendations As a result of the staffs analysis of the ROP program execution data, as well as other insights, the staff concluded that the actions taken to address the recommendations from the ANO 95003 lessons learned report have been effective for those recommendations where action was taken and sufficient data was available to assess the effectiveness. For those recommendations where no action was taken, it was determined that sufficient guidance already exists in program documents to address the bases for those recommendations. There were no unintended consequences identified for those actions that resulted in a change to the ROP. There are no recommendations resulting from this effectiveness review.
ML22349A505 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB NAME RCureton PMcKenna DATE 12/22/2022 2/7/2023