ML24004A161

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December 15, 2023, Summary of Public Meeting to Discuss Corporate Level Inspections
ML24004A161
Person / Time
Issue date: 01/17/2024
From: Amar Patel
NRC/NRR/DRO/IRIB
To: Hartman T
Office of Nuclear Reactor Regulation
References
Download: ML24004A161 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:

Thomas Hartman, Acting Chief Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:

Amar Patel, Reactor Operations Engineer Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF DECEMBER 15, 2023, PUBLIC MEETING TO DISCUSS CORPORATE LEVEL INSPECTIONS On December 15th, 2023, the Office of Nuclear Reactor Regulation staff hosted a webinar Observation meeting (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML23333A048), with representatives from the Nuclear Energy Institute (NEI),

various licensee staff, and members of the public to discuss corporate level inspections.

During the meeting, the NRC staff presented discussion areas for the industry to consider when proposing consolidation of inspections at a corporate location. NRC staff provided the discussion areas such as what NRC inspections should be considered for corporate inspections, how would any issues found be adjudicated, how would those corporate level inspections fit in the ROP, how would corporate inspection increase effectiveness and efficiencies, what could be some unintended consequences, and what other ROP changes should we consider.

NRC facilitated the meeting, allowing industry to share their ideas in the specific discussion areas. Representatives from NEI, NextERA, Constellation, TVA and Duke presented their viewpoint specific to the discussion areas. Most common, the industry representatives would like increased inspection flexibility such as common level program/procedure inspections should not be duplicated from site to site that implement the common level program/procedures. The industry mentioned few inspections that can be partly conducted at the corporate facilities such as commercial grade dedication, age related degradation, comprehensive engineering team inspection, fire team inspections, cyber security team inspections, 50.69 inspections, and steam generator tube inspections. Industry representatives also mentioned a module approach such as the first site would get the whole inspection and subsequent sites within that fleet would get self-assessments based on the results of the first site inspection. Another approach that was mentioned that the NRC should conduct one aspect of the inspection at the corporate facility and then conduct the walkdowns at the specific sites at another time. Representatives from the industry mentioned that any potential violations found at the corporate facility that the specific site that was inspected first should get the violation and any subsequent site would potentially get credit for entering the issue into their corrective action program and those violations maybe licensee identified. Industry also mentioned that any issues found at the corporate level, inherently would be addressed at all their sites and therefore the NRC could have a single January 17, 2024 Signed by Hollcraft, Z on 01/17/24

T. Hartman inspection report and document multiple dockets in that report. The industry also gave an example of an inspection being completed within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> and that the first time an inspection is completed, 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> could be done at the corporate offices and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> completed at the individual site. Any subsequent inspection completed at other facilities within that fleet should only get the 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> onsite inspection. The industry also mentioned that if inspections were consolidated then that would free up their staff to concentrate on improving safety instead of their time supporting NRC inspections. The industry also mentioned that some of their facilities cross regional boundaries and it could increase effectiveness of inspections such as team leaders from various regions may be able to gain consistencies by visiting the corporate facilities at the same time and share inspector information. The industry also mentioned that based on 20 years of ROP experience, maybe the NRC should evaluate those 20 years and have an opportunity to enhance the ROP.

The NRC staff presentation can be found at ADAMS Accession No. ML23332A720. The NRC staff allowed industry and the public to provide questions, comments and feedback on the corporate level inspections. NRC staff and industry conducted an open dialogue discussing the industry comments.

This meeting was a virtual webinar meeting. At designated points during the meeting, members of the public were invited to provide any comments on the presentations. There were no comments from the public during the meeting.

Enclosure:

Lists of Attendees CONTACT: Amar Patel, NRR/DRO 610-337-5220

T. Hartman

SUBJECT:

SUMMARY

OF DECEMBER 15, 2023, PUBLIC MEETING TO DISCUSS CORPORATE LEVEL INSPECTIONS DATED: JANUARY 17 2024 DISTRUBTION:

RidsNrrDroIrib Resource APatel DBollck ADAMS Accession Nos.: ML24004A161 OFFICE NRR/DRO/IRIB NRR/DRO/IRIB NAME APatel DBollock DATE 1/3/2024 1/17/2024 OFFICIAL AGENCY RECORD

LIST OF ATTENDEES FOR THE DECEMBER 15, 2023, PUBLIC MEETING TO DISCUSS CORPORATE LEVEL INSPECTIONS Name Organization Name Organization Thomas Hartman NRC Tim Riti NEI Amar Patel NRC Steve Catron NextERA Douglas Bollock NRC Cecil Fletcher Duke Phil McKenna NRC Christian Williams Constellation Antonios Zoulis NRC Russell Thompson TVA Chris Caufman NRC Tony Brown NEI Don Johnson NRC Kevin Ellis Duke Greg Warnick NRC Stephenie Pyle Nick Taylor NRC Tracy Orf Ken Kolaczyk NRC Harry Balian PSEG Jeff Bream NRC Timothy Falkiewicz NextERA James Baptist NRC Enrique Melendez Theo Fanelli NRC Charlene Chotalal Dominion Scott Sullivan NRC Larry Nicholson Certrec Mel Gray NRC Kenneth Mack NextERA Joshua Green NextERA Suzanne Loyd Constellation Deann Raleigh Curtis Wright Mary Miller Dominion Jeff Connors Xcel Energy Brian Derrico NextERA James Orr Constellation Jeanne Johnston Southern Kimberly Hulvey TVA Jim Anderson Excel Services Camille Zozula Westinghouse Andrew Mauer NEI Brian Mount Dominion Enclosure