ML23108A169

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Summary of the Reactor Oversight Process Bi-Monthly Public Meeting
ML23108A169
Person / Time
Issue date: 04/18/2023
From: David Aird
NRC/NRR/DRO/IRAB
To: Philip Mckenna
NRC/NRR/DRO/IRAB
References
Download: ML23108A169 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 18, 2023 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

SUBJECT:

SUMMARY

OF THE REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING HELD ON APRIL 5, 2023 On April 5, 2023, 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.

ROP Enhancements for Assessment Inputs The NRC staff provided an overview of the status of implementing Commission direction in SRM-SECY-22-0086, Recommendations for Revising the Reactor Oversight Process Assessment Program, dated March 10, 2023. The staff described planned changes to Inspection Manual Chapter 0305, Operating Reactor Assessment Program, to implement the new Commission policies to allow closure of greater-than-Green inspection findings upon satisfactory completion of the appropriate supplemental inspection, and to revise the treatment of greater-than-Green Performance Indicators (PIs) to remain as Action Matrix inputs until satisfactory completion of the appropriate supplemental inspection. The closure date for inspection findings will be the exit meeting date for the successful supplemental inspection, or re-exit meeting date if applicable. The staff briefed that the definition for a held open finding was being changed to a finding that remains open when a licensee does not satisfy all objectives of the supplemental inspection, and the date of closure for a held open finding would be the date of issuance of the satisfactory supplemental inspection and assessment follow-up letter.

Industry representatives stated that they thought the closure date for held open findings should be the exit meeting date for the satisfactory completion of the supplemental inspection to be consistent with the closure date for those findings where the objectives of the supplemental inspection were satisfied the first time.

CONTACT: David M. Aird, NRR/DRO 3012870725

P. McKenna The revised treatment for PIs will be issuance of a parallel PI finding with the same color as the PI that will act as the Action Matrix input until satisfactory completion of the appropriate supplemental inspection. Parallel PI findings will be treated the same as inspection findings. The staff also discussed options for a licensee that continues to accrue occurrences to the PI after satisfactory completion of the supplemental inspection.

Presentation: ROP Enhancement Changes to Assessment Program - ML23086C004 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23086C004 Commercial Grade Dedication Inspection Updates The NRC staff provided an update on the Commercial Grade Dedication (CGD) inspections.

Staff shared that training of the NRC inspection staff was completed for the CGD inspections, that the first CGD inspections were completed, and that CGD inspections had at least started in each region. Staff also indicated that NRC cross-regional panels will be held following the inspection completion prior to the inspection report issuance. Staff shared some initial lessons learned, primarily that licensees need to make sure the correct people within their organizations are involved, including procurement engineering, and that some of the licensee staff involved with CGD inspections may not have experience interacting with the NRC or site regulatory affairs staff. NRC staff encouraged early and often communications between licensees and the NRC inspectors and indicated that each licensee may have different terminology than others, and encouraged licensee staff to ask inspectors for more clarity if they are unsure what specifically the inspection team is requesting.

Overall, CGD inspection implementation has been a success. NRC staff also shared that the NRC will be holding a virtual public meeting on the next new inspections, Age-Related Degradation, on Tuesday, April 18 at 10:00am. The public meeting announcement can be found on the NRCs public website and at ML23100A055.

The NRC staff also shared that the Commission voted and provided staff direction on SECY 0087, Recommendation for Problem Identification and Resolution Team Inspection Frequency.

The Commission directed staff to maintain the current frequency of and current number of inspection hours for Problem Identification and Resolution inspections. The Commission also directed staff to reinstate the minimum inspection hours and minimum samples for the newly combined post-maintenance testing and surveillance testing inspection. Inspection Procedure 71111.24 Testing and Maintenance of Equipment Important to Risk was updated to reflect the Commission direction and can be found at ML23062A724.

Presentation: Commercial Grade Dedication Inspection Updates - ML23088A394 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23088A394 OE/KM: ANS Changes Made by OROs with Licensee Impact The NRC staff provided information related to an issue that occurred when several offsite response organizations (OROs) changed their backup Alert and Notification System (ANS) methods without a commensurate revision to the FEMA approved ANS Design Report. The staff reminded licensees of their responsibilities with ANS, primarily as reflected in Appendix E to 10 CFR 50, Part IV.D.3, and encouraged licensees to maintain awareness of this issue and recommended they maintain an open line of communication with OROs when OROs are making changes that may impact licensee requirements.

P. McKenna The staff provided a letter from FEMA related to this issue, FEMA Approval of ANS Design Report for Constellation Midwest OROs, (ML23073A021).

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23073A021 NEI asked about the impact this issue has on the SECY for removal of the ANS-PI and the staff answered that backup ANS availability does not have a PI associated with it and therefore does not impact the SECY or any ANS-PI reporting requirements.

NRC Response to FAQ 23-01 The NRC discussed the proposed response to FAQ 22-03, related to a DC Cook reactor trip occurring on May 22, 2022. The FAQ was submitted to request a one-time exemption from the guidance related to Unplanned Scrams per 7,000 Critical Hours. High vibrations were encountered while attempting to return the unit to service following significant turbine maintenance. The maintenance included the complete replacement of all interstage and shaft gland labyrinth seals. The staffs position was that the DC Cook reactor trip was an unplanned scram by the definition stated in NEI 99-02, Revision 7. The expected response described in the FAQ would only happen in the event of high vibrations outside of pre-established limits, indicating that a scram was a possibility and not a certainty.

The May 24, 2022, DC Cook reactor scram was an initiating event, and the objective of the initiating events cornerstone is to limit the frequency of those events that upset plant stability and challenge critical safety functions, during shutdown as well as power operations. When such events occur in conjunction with equipment and human failures, a reactor accident may occur.

Considering the objective of the initiating events cornerstone and the circumstances of the scram being of high likelihood as opposed to an inevitable function of the evolution, the staff did not approve of a one-time exemption of IE01 - Unplanned Scrams per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

During the meeting, the NRC staff provided the following as background information for the topic:

FAQ 23-01 DC Cook Unit 1 Unplanned Scram Exemption Request - ML23090A226 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23090A226 Proposed Industry FAQs Industry representatives discussed an upcoming white paper on proposed Vogtle 3 performance indicator exemptions.

Discussion of the Safety Culture Effectiveness Review Recommendations The NRC staff discussed the recommendations for the Safety Culture Effectiveness review. This was a follow-up to the November 17, 2022 public meeting discussion of the effectiveness review and data analysis portion of the review. The working group report was issued on March 20, 2023 in time for industry to review the recommendations prior to this meeting. The staff also explained that the report was the working groups recommendations, and that NRC management would decide in the future what recommendations or parts of recommendations to implement. Industry representatives discussed concerns with the recommendation to revise the P. McKenna inspection procedures associated with safety culture and the teams recommendations to add a baseline inspection procedure into the ROP inspection program. NEI stated that the NRC Commissions direction on a graded approach to Safety Culture oversight was intentional and that the working group recommendations increase oversight in Licensee Response and Regulatory Response Columns in the ROP Action Matrix. NEI also stated that they would be providing a letter to the NRC which will discuss the industry concerns in more detail. NRC senior management committed to further discussion on this topic at a future public meeting related to the final decision on the recommendations and any implementation plans.

Report: Results of the Safety Culture Program Effectiveness Review - ML22340A452 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22340A452 Presentation: 2022 Self-Assessment: Safety Culture Effectiveness Review - ML23082A044 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23082A044 The Next ROP Meeting The next ROP bimonthly public meeting is tentatively scheduled for May 18, 2023.

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 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 (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 following link contains the meeting agenda and other information:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23090A151 The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML23108A169 * = via email OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME DAird PMcKenna* DAird DATE 4/14/2023 4/17/2023 4/18/2023 LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING April 5, 2023, 9:00 AM to 11:30 AM Name Organization1 Name Organization Tim Riti NEI David Aird NRC Tony Brown NEI Mike King NRC Steve Catron NextEra Phil McKenna NRC Ken Mack NextEra Russell Felts NRC Brian McCabe NEI Julio Lara NRC David Mannai PSEG Mike Hay NRC Brett Titus NEI Don Johnson NRC Lori Grusecki APS Palo Verde Aron Lewin NRC Sebastian Larrea Dominion Andrea Johnson NRC Stephenie Pyle Entergy Naeem Iqbal NRC Russell Thompson TVA Billy Gleaves NRC Nicole Good STARS Alliance Rebecca Sigmon NRC Edwin Lyman UCS Christopher Tyree NRC Robin Ritzman Curtiss-Wright Dan Merzke NRC Larry Nicholson Certrec Maury Brooks NRC David Gudger Constellation Nuclear Larry Grimes NRC Phil Couture Entergy Amy Hardin NRC Donald Lamirande Constellation Nuclear Hang Vu NRC Rob Burg EPM, Inc. Sarah Obadina NRC Richard Montgomery PSEG Bridget Curran NRC James Pak Dominion Energy William Rautzen NRC Marty Murphy Xcel Energy Brian Hughes NRC Ryan Joyce Southern Nuclear Marcus Chisolm NRC Charlene Chotalal Dominion Energy David Garmon NRC Deann Raleigh Curtis-Wright Tom Hipschman NRC James Bremer Xcel Energy Ron Cureton NRC Melody Rodriguez NEI Gabe Taylor NRC Harry Balian PSEG Ekaterina Lenning NRC Dylan Graves Unknown Julie Winslow NRC Kevin Ellis Duke Energy Keith Boring NRC Cecil Fletcher II Duke Energy Cheryl Khan NRC Michael Scarpello AEP Mike Ordoyne NRC Steve Mitchell AEP Andrew Mihalik NRC Jigar Patel Dominion Energy Amar Patel NRC Darlene Delk TVA Mike McCoppin NRC Drew Richards Unknown David Kern NRC Carrie Seipp Xcel Energy Brigit Larsen NRC Linda Dewhirst NPPD Ravi Penmetsa NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Enclosure

Name Organization1 Name Organization Lloyd Generette Unknown John Hughey NRC B. Cizin Unknown Brian Griman NRC Kimberly Hulvey TVA Vince Voltaggio NRC Carlos Sisco Winston & Strawn Manuel Crespo NRC William Garrett Southern Nuclear Raju Patel NRC David Young NEI John O'Donnell NRC Thomas Basso NEI Michele Kichline NRC Enrique Meléndez Consejo de Jonathan Lizardi- NRC Seguridad Nuclear Barreto Tony Zimmerman Duke Energy Mark Hagen NRC Jim Slider NEI Doug Bollock NRC Jason Eargle NRC Eric Bowman NRC Jimmy Chang NRC Shawn Lichvar NRC 2