ML23013A078

PI&R Inspection Discussion for January 2023 ROP Public Meeting

ML23013A078
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/13/2023
From:	Riti T Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
References
Download: ML23013A078 (1)

Text

PI&R Inspection Discussion ROP Public Meeting January 18, 2023

©2023 Nuclear Energy Institute 1

Purpose Provide additional insights on the PI&R Inspection Program following the ROP Task Force review of SECY-22-0087

©2023 Nuclear Energy Institute 2

Overview We agree that PI&R program enhancements are warranted The NRC staff identified some enhancements that would have benefited from a decrease in team inspection frequency We see all enhancements as complementary to an effective PI&R program consistent with the Principles of Good Regulation

©2023 Nuclear Energy Institute 3

=

Background===

There have not been any substantive changes to the PI&R IP 71152 since 2005 SECY-19-0067 (ROP Enhancements) submitted to the Commission June 2019

• Recommended revising PI&R inspection (team portion) from biennial to triennial Credits the semi-annual and annual portions of PI&R inspection requirements to prioritize, evaluate and correct conditions adverse to quality Other baseline inspection procedures include 10 - 15% PI&R inspection scope related to CAP in applicable inspectable area

©2023 Nuclear Energy Institute 4

=

Background===

Comprehensive review of PI&R inspection program completed November 2020 recommending small enhancements

• Supports both the current biennial & proposed triennial team inspection frequencies

• Addresses inspector feedback to improve clarity of inspection guidance to enhance consistency (reduces inspection overlap)

Team inspection scope would be on licensee implementation of PI&R program focusing on identification, prioritization, evaluation, and corrective action Audits, Self-Assessments, and Operating Experience reviews will allow redistribution of inspection resources to improve efficiency Duplicative guidance that overlaps with annual and semiannual samples would be removed Changes will be implemented prior to start of next inspection cycle in 2024

• In January 2022, the daily resident PI&R screening was moved to IMC-2515 to improve inspection hour tracking

©2023 Nuclear Energy Institute 5

=

Background===

SECY-19-0067 was withdrawn August 2021 to reevaluate all ROP enhancement recommendations SECY-22-0087 submitted to the Commission September 2022 to reconsider the PI&R team inspection frequency with two options

• Option 1: Maintain the current biennial inspection frequency

• Option 2: Decrease the inspection frequency to triennial NRC staff recommended maintaining the frequency at biennial

• No new information or rigorous technical basis was provided for changing the original recommendation

• The results of the comprehensive review of PI&R and recommended enhancements were referenced as the bases for maintaining the current inspection frequency (even though the comprehensive review accounted for a change in frequency)

©2023 Nuclear Energy Institute 6

PI&R Inspection Scope PI&R is inspected every day through plant status activities Over 20% (~625 hours) of all direct inspection hours focus on PI&R programs

• Semiannual Trend Review - 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> (40 annualized hours)

• Annual Follow-up of Selected Issues (74 annualized hours)

• Biennial Team Inspection - 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> (125 annualized hours)

• PI&R review during ROP baseline inspections 15% (209 annualized hours)

• Daily through plant plant status activities - IMC-2515, App. D (177 annualized hours)

©2023 Nuclear Energy Institute 7

PI&R Finding Trends Chart from SECY-22-0087 The total number of PI&R inspection findings have decreased significantly since 2010 Similar trend for biennial team inspection portion of IP 71152 (less than 10 findings annually since 2018)

Most PI&R inspection findings come from the elements of IP 71152 that are not part of the biennial team inspection (i.e., semiannual, annual, and 10-15% of all baseline inspections)

©2023 Nuclear Energy Institute 8

Other Insights The original staff recommendation to change the PI&R inspection (team portion) frequency from biennial to triennial would only reduce the PI&R inspection related annualized hours from ~625 to 583 This represents ~1.5% decrease in all annual direct inspection hours {PI&R activities would continue to represent greater than 20%}

Based on 2021 data:

• 1 PI&R finding was identified for approximately every 4500 inspection hours (other than biennial team inspections)

• 1 PI&R finding was identified for approximately every 22,500 inspection hours during biennial team inspections

• This reinforces that significantly more PI&R findings are identified through the PI&R inspection elements outside of the PI&R team inspection

©2023 Nuclear Energy Institute 9

Summary Enhancement to the PI&R inspection program remains appropriate A triennial PI&R inspection frequency remains justified as described in SECY-19-0067 Changing from biennial to triennial would permit corrective actions to have more time to effect change while negligibly reducing the NRCs oversight of PI&R programs We encourage the NRC staff to continue efforts to enhance IP 711152 to improve clarity to support inspection consistency and reduce overlap that exists in the current guidance while awaiting a decision on SECY-22-0087 We look forward to engaging on the proposed changes as they are being developed to support implementation starting in 2024

©2023 Nuclear Energy Institute 10

Questions

©2023 Nuclear Energy Institute 11