ML23166B131

M230620: Slides/Supporting Presentation Material - Staff - Briefing on Results of the Agency Action Review Meeting

ML23166B131
Person / Time
Issue date:	06/15/2023
From:	NRC/OCM
To:
Shared Package
ML23110A703	List: ML23166B129 ML23166B131 ML23166B133
References
M230620
Download: ML23166B131 (1)

Text

Briefing on the Results of the Agency Action Review Meeting June 20, 2023

Agency Action Review Meeting (AARM) Objectives 01 02 03 04 Review the Review Nuclear Review Ensure that trends appropriateness of Materials and effectiveness of the in licensee NRC actions taken Waste Safety Reactor Oversight performance are for licensees with Program Process (ROP) and recognized and significant Performance and the Construction appropriately performance issues Trends ROP addressed 2

Agenda Theresa Clark

- Nuclear Materials and Waste Safety Program Performance and Trends Russell Felts

- CY 2022 ROP Self-Assessment Results

- COVID-19 Lessons Learned for the ROP

- Inspection Findings Trend Andrea Johnson

- CY 2022 cROP Self-Assessment Results Joshua Borromeo

- Overview of NIST Event and NRC Response 3

Nuclear Materials and Waste Safety Program Theresa Clark, Deputy Director Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards

Sound Licensee Performance in the Nuclear Materials and Waste Safety Program Systematic review of information to identify significant:

• Operational performance issues

• Licensee performance issues

• NRC program issues/gaps No nuclear materials licensee met the significant performance issue criteria in SECY-11-0132 for FY2022.

5

Safety and Security Goals Met

• Fuel Facilities

• Decommissioning and Low-level Waste

• Spent Fuel Storage and Transportation

• Nuclear Materials Users o Met performance indicators for licensing, inspection, enforcement, and allegations o Did not meet NM-23, Percentage of Materials Programs with More than One Unsatisfactory Performance Indicator 6

Fewer Events for Nuclear Material Users 7

Nine Abnormal Occurrences in FY2022

• 7 medical events

• 2 overexposures

• No significant trends

• Number of medical events is small relative to the millions of procedures involving the use of radioactive material 8

A Healthy National Materials Program

• 13 IMPEP reviews of Agreement State materials programs conducted in FY2022

• 39 Agreement States o 35 programs adequate and compatible o 3 programs on Heightened Oversight o 1 program on Probation

• Assessing programmatic enhancements 9

Integrating and Modernizing the Materials and Waste Program

• Operating experience assessments

• Coordinated approach to oversight and qualifications

• Standing committee for reviewing emerging medical technologies 10

Many Successes in FY2022

• No significant trends

• Transitioned out of pandemic

• Innovating and risk-informing across all NMSS program areas 11

ROP Self-Assessment, COVID-19, and Inspection Findings Trend Russell Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation

ROP Self-Assessment Program Did the ROP Did the ROP meet its meet its program intended goals?

outcomes?

Was the ROP implemented per Did ROP current governance execution adhere documents, and was to the Principles it implemented of Good uniformly across all ROP Self-Regulation?

offices and regions? Assessment Program 13

CY 2022 ROP Self-Assessment Results

• The ROP provided effective oversight of operating reactors

• The ROP was implemented in accordance with the Principles of Good Regulation (Independence, Clarity, Openness, Reliability, and Efficiency)

• The ROP supports the agencys strategic goals:

• To ensure the safe and secure use of radioactive materials

• To continue to foster a healthy organization

• To inspire stakeholder confidence in the NRC 14

ROP Self-Assessment Activities in CY 2022 Element 1

• Performance Metrics

• Data Trending

• Program Area Evaluations, Including Significance Determination Process (SDP) Timeliness Review

• Implementation Audit of Region I Element 2

• Effectiveness Review of the Incorporation of Safety Culture into the ROP (started)

• Effectiveness Review of Recommendations from IP 95003 Lessons Learned

• ROP Lessons Learned Tracker Element 3

• Baseline Inspection Program Monitoring - DRO only 15

CY 2022 ROP Performance Metrics Results

• IMC 0307, Appendix A

• 2 red metrics, still due to the impact of the COVID-19 public health emergency

• I-3 Manager Objectivity Reviews

• I-4 Qualified Staff

• 2 yellow

• I-5 Resident Site Staffing

• E-3 SDP Completion Timeliness

• 13 green

• R-2 No ROP Action Matrix deviations

Plans for CY 2023 ROP Self-Assessment Activities Element 1: Measure Element 2: Assess Regional and Effectiveness of Recent Element 3: Perform Headquarters ROP Changes and Focused Assessments Program Evaluate the NRCs of Specific ROP Program Effectiveness and Response to Significant Areas, Including the Uniformity Licensee Events or Baseline Inspection Implementing the Declining Licensee Program ROP Performance

• Performance Metrics

• Continue the Effectiveness

• Baseline Inspection Program

• Data Trending Review of Safety Culture Monitoring - DRO only

• Program Area Evaluations

• Lessons Learned Tracker (Including Review of Baseline Security SDP)

• Implementation Audit of Region II 17

ROP through COVID-19 Current and future intent is to perform inspection activities on site and to complete the nominal baseline inspection; ROP has built in flexibilities

• NRR issued a cancellation memo on April 21, 2023, which rescinded the ROP inspection guidance in place due to COVID-19. NMSS also issued a comparable memo.

Comprehensive Baseline Inspection Program Review

• Focused on lessons learned during COVID-19 and flexibilities to complete future baseline inspection

• Completed November 2021 Follow-on Review of Lessons Learned, Best Practices, and Challenges

• Included engagement opportunities with internal, external, and international stakeholders

• Identified potential enhancements to the program for both normal and abnormal situations

• Completed July 2022

• A working group is being chartered to implement selected recommendations 18

Inspection Findings Trend

• Clear downward trend in number Green ROP Inspection Findings of green ROP inspection findings began in 2015 through 2020, but 300 1st Qtr has increased each of the past two 250 2nd Qtr years 3rd Qtr 200

• The average number of findings 4th Qtr per site decreased by 150 approximately 1.5 findings per site 100 each year from 2015 through 2020 50

• In CY 2022, the ROP had approximately 6.8 findings per site 0 (4.0 findings per unit), comparable to the number of green findings issued in 2019 19

Construction ROP Andrea Johnson, Senior Project Manager Division of Construction Oversight Region II

Vogtle Unit 3 Successful transition from cROP to ROP Transition to after the 10 CFR ROP 52.103(g) finding 21 21

Vogtle Unit 4 Construction Reactor Oversight Process Ensuring Strong and Effective Oversight

• Successful cROP implementation

• No cROP Action Matrix deviations in CY 2022

• ITAAC, initial test and operational programs coordination

• Targeted ITAACs 22

Lessons Learned Nurturing a Culture of Continuous Learning

• Unit 3 post 10 CFR 52.103(g) finding audit

• Informing future construction oversight program

• Vogtle Readiness Group (VRG)

• Enhanced inspection strategies

• Lessons learned initiative

• Late Filed Allegations (LFA) 23

Overview of NIST Event and NRC Response Joshua Borromeo, Branch Chief Nonpower Production and Utilization Facilities Licensing Branch Division of Advanced Reactors and Nonpower Production and Utilization Facilities Office of Nuclear Reactor Regulation

NIST Test Reactor

Background

• Located on the NIST campus in Gaithersburg, MD

• Normally Operated 24/7

• Refueling ~50 days

• Plate-type fuel with 34 plates per element and up to 30 elements in the core

• Non-pressurized heavy water primary cooling system with helium cover gas

• Carbon and HEPA filtered emergency exhaust ventilation and recirculation cleanup 25

Event Overview

• On February 3, 2021, operators were raising power level from 10 MW to 20 MW

• Increasing radioactivity at the exhaust stack monitor automatically shut down the reactor

• All safety systems functioned properly

• No significant radiological consequences for workers, the public, or the environment

• The cause of the event was a fuel element not properly latched

• Displaced element overheated and fuel melted 26

NIST Oversight Timeline Confirmatory order Restart Restart and supplemental authorization and Emergency alert authorization inspection plan technical evaluation event request issued report issued 3 Feb. 2021 1 Oct. 2021 1 Aug. 2022 10 Mar. 2023 9 Feb. 2021 16 Mar. 2022 7 Mar. 2023 16 Mar. 2023 Special inspection Special inspection Supplemental NIST test reactor began report issued inspection report restarted issued 27

Special Inspection and Enforcement

• NIST restart authorization request identified

• 7 root causes

• 23 corrective actions

• Special inspection team (SIT) assessment

• 7 apparent violations

• Mediated alternative dispute resolution

• agreement to corrective actions and timelines

• Confirmatory order 28

Technical Review of Restart Request

• Review of the event and corrective actions

• Review ensured no functional damage:

• Effectiveness of clean-up activities

• Primary coolant system with potential remaining debris

• NIST will not reuse any fuel in the core during event

• Confirmed adequacy of limiting safety system settings and maximum hypothetical accident 29

• Enhanced NRC oversight since the event

• Special inspection informed corrective actions

• Supplemental inspections assessed the effectiveness of completed corrective actions

• Inspection areas

• Emergency response (equipment, NRC procedures)

Oversight

• Fueling, defueling, latching procedures

• Primary system clean-up and restart core

• Start-up and abnormal conditions procedures

• Operator and supervisor training

• Safety Culture 30

Restart Authorization Evaluation of safety systems and components Corrective actions and enhancements to prevent recurrence Additional enhancements to improve safety Increased NRC oversight 31

Post-Restart Oversight

• Staff observed improvements in key areas of NIST operations since the event

• The NRC staff will continue to perform supplemental inspections

• Increased NRC inspector on-site presence, including observations of fueling/defueling activities and significant maintenance activities

• The NRC staff will continue to assess NISTs implementation of corrective actions and confirm completion of Confirmatory Order actions

• Increased oversight of the NIST reactor will continue until routine inspections are appropriate 32

Introspective Look Continuing to learn and improve

- No significant gaps identified in regulatory oversight framework for RTRs

- Enhancements to inspection samples

- Sharing of RTR operating experience

- Enhancements to reactive inspection decision-making and internal emergency response for RTR events

- Opportunity for further insights as NIST implements corrective actions 33

Conclusion The NRC staff affirmed the appropriateness of agency actions and the effectiveness of our oversight programs 34

List of Acronyms

• 52.103(g) OR 103(g) - Title 10 of the

• IMC - Inspection Manual Chapter Safety and Safeguards Code of Federal Regulations section

• IMPEP - Integrated Materials

• NRC - U.S. Nuclear Regulatory 52.103(g)

Performance Evaluation Program Commission

• AARM - Agency Action Review

• IP - Inspection Procedure

• NRR - Office of Nuclear Reactor Meeting Regulation

• IMC - Inspection Manual Chapter

• COVID Coronavirus Disease

• ROP - Reactor Oversight Process 2019

• ITAAC - Inspections, Tests, Analyses, and Acceptance Criteria

• RTR - Research and Test Reactor

• cROP - Construction Reactor Oversight Process

• LFA - Late-Filed Allegations

• SDP - Significance Determination Process

• CY - Calendar Year

• MD - Management Directive

• SIT - Special Inspection Team

• DRO - Division of Reactor Oversight

• MW - Megawatt

• VRG - Vogtle Readiness Group

• FY - Fiscal Year

• NIST - National Institute of Standards and Technology

• HEPA - High Efficiency Particulate Air

[Filter]

• NMSS - Office of Nuclear Material 35