ML24308A002
| ML24308A002 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/2024 |
| From: | Lundy Pressley NRC/NRR/DRA/APOB |
| To: | |
| References | |
| Download: ML24308A002 (4) | |
Text
Enclosure 1 PRA Configuration Control OpESS Panel Template Note: The standard IMC 0611 four-part write-up can be submitted in lieu of this worksheet.
Date of Panel email Inspection Date Sept 9-13, 2024 Licensee X Exit Date Debriefed 9/13/24 Region I Report Number Feeder to 2024003 IRAB BC (Panel Chair)*
David Aird APOB BC* Antonios Zoulis Regional BC* Sarah Elkhiamy Regional SRA Werkheiser, Arner DRO or DRA SRA/RRA*
Lundy Pressley Lead Inspector Jim Kepley Regional Enforcement Coordinator*
Lauren Casey NRR Enforcement Coordinator Other Staff
- Voting member and required for quorum Performance deficiency (including regulation or standard not met)
PI&R Observation; minor issue. No PD.
Brief summary of the issue Minor/more-than-minor (including basis) and proposed significance The Region believes this is a minor issue since there was no adverse impact to the cornerstone objective (similar to PCC minor examples 1 & 2, ML24152A029)
During a PI&R sample follow-up at X of a Time Critical Operator Action (TCOA), the inspector noted (and discussed with regional SRAs) inconsistent feedback to the stations PRA model when operator training periodicities are changed. The initial validation of TCOAs and inclusion into the PRA appeared satisfactory, but the governing fleet procedures did not clearly require the engagement of PRA staff to evaluate impact when operator training changes were implemented since the last PRA model update.
Though this was not a pre-planned OpESS, based on discussions with the inspector and branch, the SRAs recommend this be tagged in the report as a sample for tracking IAW OpESS 2023-002 (elements in section 03.02). The SRI will exit the quarterly report and note that this PI&R sample result is related to OpESS 2023-002.
Draft PI&R Sample result is copied in COMMENTS below.
PRA Configuration Control OpESS Panel Template Cross-cutting aspect and basis N/A Enforcement (if applicable)
N/A Comments Draft PI&R Observation text below:
Title:
Verify Completeness and Accuracy of Time Crical Operator Acon Validaons Observation:
The inspectors noted that validaon acvies for me crical and me sensive acons are not always being performed in accordance with (IAW) the program requirements and consistent with probabilisc risk assessment (PRA) calculaons. OP-AA requires re-validaon to be performed for certain acvies every 6 years. Some re-validaons were performed outside this frequency. Addionally, inspectors noted that a validaon plan for a me sensive acon was observed to contain a validaon methodology not consistent with the associated PRA calculaon. Addionally, the inspectors noted that operator training frequencies assumed in the PRA calculaons were not consistent with current operator training task frequency.
Time Sensive Acon - 3X is to perform DC Load shedding in the event of a staon black out (SBO). TSA-2X is to perform a similar load shedding for an ELAP which is all of the TSA-3X acons plus an addional set of loads are shed using Flex Support Guidelines.
The staon procedure to implement SBO load shedding is SE-a. These acons were validated, along with the TSA-2X acons to ensure that they could be performed within the meframe assumed in the plant PRA, which is xx minutes. The validated acon meframe as documented in the staons OP-PB to perform SE-a is Z min z sec which is less than the max allowable me.
Fire PRA PB-PRA-, Revision 1 sequence EF provides a detailed risk assessment of the SE-a acons. It states on page A-x that Operator acon success criterion: Complete the SE-a load shed steps before Z minutes from the loss of AC power to the baery chargers. The actual plant validaon sheet performed on x/xx/x provided by Operaons states that the validaon Time Zero is when the Equipment operators are directed to perform the SE-a acons.
The me assumed in Fire PRA PB-PRA-, Revision 1 sequence EF for delay/cognive recognion of the SBO, performing the required trip procedures and then direcng the appropriate aachments of SE-a is Z min.
This meframe was not validated by Operaons while validang TSA-b. Since the me validaons were performed with one "eld operator and the PRA assumes two would be available, the inspectors believe that sucient me to perform the task successfully would be valuable.
It was recognized that processes to inform the PRA to subsequent changes in operator acon training frequencies aer inial development are not clearly controlled. The governing corporate procedures, ER-AA-a and ER-AA-b, do not provide clear direcon for the site risk management engineer or model owner to ensure that operaons training changes since the last PRA model update are evaluated for their impact.
This was captured in IR 01. This is related to OpESS 2023-002 and considered a sample.
These issues were captured under IRs 0421, 0481 and 0478. The inspectors did not idenfy any performance de"ciencies as a result of this inspecon.
Decision Reached This issue was discussed with the PCC Working Group (WG) as part of reviewing the Regions proposed recommendation. The issue does not involve a Performance Deficiency and would only result in an observation documented in the quarterly report.
The WG agreed to provide the issue for review by means of a Modified Cross Regional Panel.
This action was taken as a means of efficiency gains given the significance and was emailed to the appropriate HQ and Regional Staff for review and any possible dissenting opinions. If any additional discussion was needed, then the review would revert to the normal panel process.
The panel agreed with the Regions approach and this issue will be documented as an observation in accordance with the recommendation. This issue is closed.