ML24213A314
| ML24213A314 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/2024 |
| From: | Ronald Cureton NRC/NRR/DRO/IRAB |
| To: | David Aird NRC/NRR/DRO |
| References | |
| Download: ML24213A314 (1) | |
Text
August 6, 2024 MEMORANDUM TO:
David M. Aird, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:
Ron Cureton, Reactor Operations Engineer Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING HELD ON JULY 17, 2024 On July 17, 2024, 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.
Revised Treatment of Greater-than-Green Performance Indicators The NRC staff briefed participants on a proposed revision to IMC 0305, Operating Reactor Assessment Program, for implementing the Commission direction to revise the treatment of greater-than-Green Performance Indicators (PIs) so that they remain ROP Action Matrix inputs until the appropriate supplemental inspection has been completed. The staff is revising the process to open a parallel PI finding with the same color as the PI if and when the PI returns to Green during a subsequent quarter and this will be the input to the Action Matrix until the objectives of the supplemental inspection are met. This will ensure a single continuous input into the Action Matrix to avoid confusion on the ROP public website, is consistent with the historical issuance of parallel PI findings, and ensures the treatment of greater-than-Green PIs is consistent with the treatment of greater-than-Green inspection findings. The staff provided two examples for implementing the new policy.
Presentation - Treatment of Greater-than-Green Performance Indicators - ML24184A170 CONTACT: Ron Cureton, NRR/DRO (404) 997-5173
Feedback on Proposed Focused Engineering Inspection Topics NEI asked questions and provided feedback on the six potential new focus areas for next inspection cycles focused engineering inspections (FEI). Most questions were regarding the intended scope of each focus area such as external hazards and electrical distribution and how they tied in with the selection criteria described in IMC 0308, Att. 2. NEI recommended against Probabilistic Risk Assessment (PRA) Configuration Control (CC) since data was still being collected from the smart sample and Setpoints as it seems to be an integral part of the scope of the current Comprehensive Engineering Team Inspection (CETI), suggested the NRC may want to consider previous FEIs (Fire Protection, EQ, POV) but didnt see Commercial Grade Dedication (CGD) or Age Related Degradation (ARD) as providing much benefit in the next inspection cycle. NEI also recommended the NRC staff continue utilizing cross regional panels following FEI inspections to ensure consistency of implementation and that the NRC staff continues discussion with industry once the next FEIs are selected and before implementation.
Examples of Licensee-Identified, NRC-Identified, and Self-Revealed Findings NEI and other industry representatives expressed that they felt the NRCs definitions and application of licensee-identified and self-revealed findings may not align with their own definitions and applications of self-identified. Also, that the examples and definitions in IMC 0612 may not closely align with the definitions in the NRC enforcement guidance. They expressed that industry strongly encourages self-identification of issues and offered that the NRC consider its existing definitions to ensure enough credit is offered for licensee self-identification. NRC managers noted that we are always willing to reflect on specific examples if any are provided. NEI will share additional examples and offer improvements of the current definitions at a future ROP public meeting.
Concept of Best Available Information in the Significance Determination Process The NRC staff discussed the development of a Best Available Information Decision Guide that is intended to aid with reviewing information discovered or provided during the significance evaluation of findings to determine if the new information should be incorporated into the NRCs decision-making. Development of this guide was an action from a review of Significance Determination Process timeliness that was completed in late 2022 (report: ML22335A003).
Discussion at this meeting noted that this would be another useful tool to help with efficient implementation of the SDP.
Presentation - Best Available Information Decision Guide - ML24193A342 Perspectives on NRCs Differing Views Program The NRC places safety as its utmost priority and has implemented a robust approach to ensure diverse views are considered during the decision-making process. The agency has formal processes for raising differing views, including the Non-Concurrence Process (NCP) and Differing Professional Opinions Program (DPO). While these avenues are available, the NRC most often leverages informal discussions and the Open Door Policy to successfully resolve issues and work through differing views. As such, the overall number of formal differing view cases are small - average of 7.5 NCPs each year for last five years, and 2.75 for DPO.
The agency has been actively looking at the current DPO and NCP processes and making improvements within the current framework. These efforts will help inform broader program
changes that may be needed to address the Advance Act requirements related to differing views. The Office of Enforcement be coordinating with the overall agency efforts related to the Act, which will include obtaining input from stakeholders and looking at practices from other organizations.
Its important to note that because the scope and complexity of DPOs can vary, the timeliness associated to dispositioning DPOs can vary as well. Factors such as the importance of prompt action on the issue, the potential safety significance of the issue, the complexity of the issue, and the priority of other work activities, can all impact timeliness. There are instances where DPOs are novel (i.e., first of a kind) and complex, requiring significant resources to disposition the DPO, and there may also be emerging needs to balance higher priority or more safety significant work, which can potentially result in increased time needed to disposition the DPO.
Other Items / Open Discussion The NRC staff acknowledged receipt of a NEI 99-02 white paper related to the unplanned scrams PI (ML24185A209) and proposed next steps in the ongoing NRC staff review of draft NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 8. A standalone meeting to discuss the white paper and other questions and comments related to the draft NEI 99-02 Revision 8 may be necessary.
NEI asked about the NRCs efforts on centralized inspection path forward. The NRC staff indicated that they were coordinating with the responsible region and inspection team lead for the specific request from the previous ROP public meeting, which was the possibility of using the same or similar inspection sample from a previous CGD inspection at an Entergy site for the upcoming CGD inspection at River Bend Station. The NRC staff also discussed the potential to test using the same inspection team at two sites with the same corporate owners in a back-to-back schedule, with part of the inspection for both occurring at the centralized corporate location to see if there are any efficiencies gained while maintaining the inspection performance based and within the bounds of the ROP.
NRC staff shared insights from the first use of the PRA CC Operating Experience Smart Sample (OpESS), (2023/02), (ML23255A006). NRC staff stated the following points on the initial use of the OpESS:
Based upon positive feedback, the OpESS is now considered available for general use.
OpESS inspection activities did not identify any significant issues.
Inspectors concluded the licensee was generally meeting their PRA CC regulatory requirements for their respective risk-informed programs.
The use of the OpESS was complementary with the CETI.
NRC staff concluded that the completion of the OpESS was not a significant impact on NRC and licensee staff resources.
An estimate of the inspector resources required to prepare and complete the OpESS was approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> out of a total approximate 490 budgeted hours for the CETI inspection.
NRC staff stated that these insights and observations are based upon a single data point and more information is needed for further insights.
The Next ROP Meeting The next ROP bimonthly public meeting is tentatively scheduled for September 25, 2024.
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: ML24185A198 The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
ML24213A314 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME RCureton DAird RCureton DATE 8/1/2024 8/6/2024 8/6/2024
Enclosure LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING July 17, 2024 - 9:00 AM to 11:30 AM Name Organization1 Name Organization Tim Riti NEI David Aird NRC Tony Brown NEI Mike King NRC Ken Mack NextEra Russell Felts NRC David Gudger Constellation Phil McKenna NRC Amy Chamberlain Southern Nuclear Danté Johnson NRC Justin Wearne PSEG Tom Hipschman NRC Keith Vincent NextEra Daniel Geary NRC Jorge L. O'Farrill Dominion Alex Garmoe NRC Darlene Delk TVA Ronald Cureton NRC Jack Hicks Luminant Eric Bowman NRC Justin Bouknight Dominion Francis Peduzzi NRC Nicole Good STARS Alliance Dwayne Myal NRC John Giddens Entergy William Rautzen NRC Larry Nicholson Certrec Jeff Rady NRC Deann Raleigh Curtiss-Wright Lundy Pressley NRC Marty Murphy Curtiss-Wright John Hanna NRC Micheal Smith NEI John Hughey NRC Enrique Meléndez-Asensio CSN Gabe Taylor NRC William Garrett Southern Nuclear James Gaslevic NRC Suzanne Loyd Constellation Qin Pan NRC Roy Linthicum Constellation Joshua Havertape NRC Carlos Sisco Winston & Strawn Daniel Merzke NRC Andrew Mauer NEI Douglas Bollock NRC Brett Titus NEI Matt Rich NRC Edwin Lyman UCS Nicholas Taylor NRC Carrie Seipp Xcel Energy Jack Bell NRC Andrew Zach EPW Gregory Stock NRC Jon Facemire NEI Christian Henckel NRC Rob Burg EPM, Inc.
Charles Murray NRC James Orr Constellation Karla Stoedter NRC Linda Dewhirst NPPD Rick Deese NRC Jeffrey Stone Constellation Sam Sayampanathan NRC Mimi King-Patterson TVA Gene Dipaolo NRC Robin Ritzman Curtiss-Wright Kim Lawson-Jenkins NRC Luke Alexander Greene TVA Wellington Tejada NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
2 Russell Thompson TVA Kris Smetana NRC Natasha Greene NRC Julio Lara NRC Sailesh Thapa NRC Tim Barvitskie NRC Richard Ramson NRC Jonathan Fiske NRC Aaron McCraw NRC Abiola Oshunleti NRC Steven Alferink NRC Ismael Garcia NRC Antonios Zoulis NRC Terri Spicher NRC Norbert Carte NRC Tony Nakanishi NRC Anna Starks NRC Geoffrey Miller NRC Alan Konkal NRC Melissa Ash NRC Lisa Regner NRC John ODonnell NRC Zack Hollcraft NRC Michelle Kichline NRC Myla Ruffin NRC Christopher Welch NRC Shane Sandal NRC Billy Dickson NRC Mel Gray NRC Naeem Iqbal NRC Glenn Dentel NRC Andrea Johnson NRC David Garmon NRC Tim Marshall NRC Amar Patel NRC Kobe Oley NRC Avinash Jaigobind NRC