ML23215A146

7/13/2023 Summary of the Reactor Oversight Process Bi-Monthly Public Meeting

ML23215A146
Person / Time
Issue date:	08/07/2023
From:	David Aird NRC/NRR/DRO/IRAB
To:	Philip Mckenna NRC/NRR/DRO/IRAB
References
Download: ML23215A146 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 7, 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

SUMMARY

OF THE REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING HELD ON JULY 13, 2023 On July 13, 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.

Update to Cybersecurity Minor Examples in Inspection Manual Chapter 0612 Appendix E The NRC staff presented the updates to cybersecurity minor examples in Inspection Manual Chapter (IMC) 0612 Appendix E. The presentation began with an overview of the issue screening process in IMC 0612 Appendix B for determining performance deficiencies in order to clarify that the determination of a performance deficiency occurs prior to determining whether the performance deficiency is minor or more-than-minor, and that the update to the cybersecurity minor examples in Appendix E have no impact on the issue screening process.

The cybersecurity minor examples update consisted of a clarifying change to an example regarding application of security controls and new examples in the areas of baseline configurations, ongoing monitoring and assessment, removal of unnecessary services and programs, physical access control, and vulnerability management. The updates were forwarded to the IMC coordinator at the end of July for inclusion in the next issuance of IMC 0612 Appendix E.

Presentation - IMC 0612 Appendix E Cybersecurity Minor Examples - ML23191A194 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23191A194 CONTACT: David M. Aird, NRR/DRO 3012870725

P. McKenna Cybersecurity Inspection Insights and More-than-Minor Criteria Representatives from NEI presented the industrys cybersecurity inspection insights. It was noted that cybersecurity inspections had three times the violations of other ROP inspections.

The presenter also noted that the update to IMC 0612 Appendix E addressed the issue of limited examples for cybersecurity minor violations. Industry has recommended additional considerations for issues screening of a potential performance deficiency. These recommendations may be included in future NEI guidance for the NRC to review.

Presentation - NEI Cybersecurity Presentation for July ROP Public Meeting - ML23191A063 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23191A063 Security/Natural Terrain Credited as Vehicle Barrier System As a result of technical issues experienced during this meeting, there was not adequate time available to cover this topic thoroughly. This topic is tentatively scheduled to be presented at the next ROP public meeting.

Presentation - Natural Terrain Credited as Vehicle Barrier System - ML23181A084 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23181A084 Enhancing Oversight of Probabilistic Risk Assessment Configuration Control The NRC staff presented a status update on the Probabilistic Risk Assessment (PRA)

Configuration Control (PCC) effort. NRC staff shared the observations memo (ML23136A565) from the PCC tabletop site visits. NRC staff provided the milestones and recommendations for a balanced approach to enhance oversight of PCC, specifically, utilizing an Operating Experience Smart Sample (OpESS) and details on what is the intent of an OpESS. Additionally, NRC staff shared plans to perform associated training to inspectors related to the OpESS and to generate significance and screening criteria for issues identified from the OpESS. Lastly, NRC staff provided a list of expected inspections that will most likely use the OpESS.

Presentation - PRA Configuration Control Status - ML23187A063 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23187A063 COVID Lessons Learned Working Group Update The NRC staff provided an update on COVID Lessons Learned and establishment of a working group. In July 2022, the NRC completed its Final Report for The Follow-on Review of The Lessons Learned, Best Practices, and Challenges During the Covid19 Public Health Emergency (ML22172A159). In July 2023, the NRC issued a memo (ML23086C029) dispositioning the final reports recommendations and established a working group (ML23086C054) to implement selected recommendations.

Proposed Response to FAQ 23-02 and Discussion to Finalize AP1000 White Paper The NRC staff presented a proposed response to FAQ 23-02. For the Peach Bottom Unit 2 scram, main feedwater was not capable of being restored to provide feedwater to the reactor vessel within roughly 30 minutes. During this event, the main steam isolation valves (MSIVs) were not reopened for approximately nine hours after the scram due to the need to lower differential pressure across the MSIVs and prioritizing other actions during the event. The staff P. McKenna acknowledges that nine hours would not be the minimum time needed to restore main feedwater, however, the licensee determined via simulator scenarios that under ideal conditions with no distractions or other priorities it would take a minimum of 90 minutes to restore main feedwater. This best-case time significantly exceeds the 30-minute time offered in NEI 99-02, Revision 7 as a reasonable period of time to restore main feedwater. The staff determined that the answer to Question 5 (Main Feedwater Availability) is Yes and this event should be classified as an Unplanned Scram with Complications.

FAQ 23 Peach Bottom Unit 1 Unplanned Scram with Complications Interpretation -

ML23192A121 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23192A121 ROP Whitepaper Modification of the Description of Unplanned Scrams with Complications Performance Indicator to Reflect AP1000 Design - ML23136A607 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23136A607 Update on NEI 99-02 Revision 8 Staff from NEI provided an update on the upcoming revision 8 of NEI 99-02, Regulatory Assessment Performance Indicator Guideline, incorporating approved FAQs since revision 7.

Presentation - NEI 99-02 Draft Rev. 8 Update for July ROP Public Meeting - ML23191A066 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23191A066 Dispositioning of Safety Culture Program Effectiveness Review Recommendations The NRC staff discussed the dispositioning of the Safety Culture Effectiveness Review recommendations. The Safety Culture Effectiveness Review working group report was issued on March 20, 2023 (ML22340A452) and was discussed at the April 5, 2023 ROP public meeting. Additional industry comments on the review recommendations were received at the May 18, 2023 ROP Public Meeting and in letters received from NEI (ML23191A058) and Florida Power & Light (ML23180A185). The NRC staff presented the Division of Reactor Oversight (DRO) program office recommendations that were developed from internal NRC and external stakeholder discussion and input on the working groups effort. Along with the recommendation to improve the training available to inspectors to better meet Commission objectives stated in SRM-SECY-04-0111, the program office recommendations centered around the working group report alternative recommendation which leverages the existing IMC 0305, Operating Reactor Assessment Program, ROP assessment review of licensee performance. This recommendation will revise existing assessment guidance to prompt NRC management discussions with licensees on any safety culture aspects discussed during assessment reviews. This recommendation would encourage licensee action to address safety culture aspects before significant performance degradation occurs. This recommendation would not require additional inspection or significant additional resources, consistent with the graded approach in SRM-SECY-04-0111 for licensees in Column 1 or Column 2 of the ROP Action Matrix. In addition, IP 93100, Safety-Conscious Work Environment Issue of Concern Followup, will be recommended for revision to make it a flexible tool to enable inspection of one or more elements of safety culture as appropriate. This revision will make IP 93100 a comprehensive inspection procedure that can be effectively and efficiently applied depending on the nature of the safety culture performance issues identified.

P. McKenna Industry representatives discussed concerns with the recommendation to revise IP 93100 stating that it would add subjectivity into the inspection program. Industry also stated that the revision to IP 93100 should follow the guidance on when the Commission needs to be informed or approve changes to the ROP. The NRC staff confirmed that the IP 93100 revision would be evaluated for Commission notification or approval. The NRC staff also stated that the revision to IP 93100 would be presented at a future ROP public meeting.

Presentation - Safety Culture Program Office Recommendations for July 2023 ROP Meeting -

ML23191A058 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23191A058 The Next ROP Meeting The next ROP bimonthly public meeting is tentatively scheduled for September 20, 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 and affiliation 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 and will be forwarded to the appropriate NRC staff. The Contact Us about ROP page on the ROP public website 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=ML23192A089 The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML23215A146 * = via email OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME DAird DMerzke* for PMcKenna DAird DATE 8/3/2023 8/3/2023 8/7/2023 LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING July 13, 2023 - 9:00 AM to 12:20 PM Name Organization1 Name Organization Tim Riti NEI Russell Felts NRC David Gudger Constellation Nuclear Philip McKenna NRC Ian Lynch NEI Mike King NRC Marty Murphy Scientech Tania Martinez Navedo NRC Deann Raleigh Curtiss-Wright David Aird NRC Justin Wearne PSEG Keith Boring NRC Ryan Joyce SNL David Garmon NRC Russell Thompson TVA Zackery Helgert NRC Shinya Ito Unknown Laura Pearson NRC Carlos Sisco Winston & Strawn Tony Nakanishi NRC Linda Dewhirst NPPD Lisa Regner NRC Phil Couture Entergy Gwynne Eatmon NRC Stephenie Pyle Entergy Lou McKown NRC David Mannai PSEG Patrick Finney NRC Richard Montgomery PSEG Maury Brooks NRC Travis Bennett Southern Nuclear Daniel Merzke NRC Robert Rishel Unknown Tony Bowers NRC Steven Leigh Unknown Don Johnson NRC Roy Linthicum Constellation Nuclear Brian Kemker NRC Enrique Meléndez CSN Ray Kellar NRC Richard E Hanson Dominion Energy Jasmine Gilliam NRC Brian McCabe NEI Alan Dahbur NRC Steve Catron NextEra Roni Fraser NRC Benny Ratnagaran Unknown Kim Lawson-Jenkins NRC Lawrence Keehner Constellation Nuclear Antonios Zoulis NRC Andrew Mauer NEI Ronald Cureton NRC James Slider NEI Lundy Pressley NRC Amy Huber Constellation Nuclear Shiattin Makor NRC David Feitl NEI Myla Ruffin NRC Lewis Csedrik Unknown Charles Murray NRC Gordon Koves Unknown Robert Williams NRC Jeff Conors Unknown Michael Brown NRC Dennis Sanz Unknown Scot Sullivan NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Enclosure

Name Organization1 Name Organization Mimi Nakicha King- TVA NRC Patterson Sarah Obadina Rob Burg EPM, Inc Sailesh Thapa NRC Edwin Lyman UCS Jonathan Fiske NRC Billie Garde Unknown Jeff Rady NRC Kirsten Stokes PSEG Joshua Havertape NRC Peter Bruley Unknown John Hanna NRC Alesia Cox Justice Unknown Nicole Fields NRC James Pak Dominion Energy Jack Bell NRC David Young NEI Alecia Hylton NRC Rebeca Saiz Utanda Unknown Anthony Valiaveedu NRC James Orr Constellation Nuclear Larry Nicholson Certrec Don Robinson Dominion Energy Robin Ritzman Curtiss-Wright Luke Greene TVA Michael Whitlock Dominion Energy Justin Bouknight Dominion Energy Ken Heffner Public 2