ML25174A222
| ML25174A222 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/2025 |
| From: | Alex Garmoe, Rebecca Sigmon NRC/NRR/DRO/IOEB |
| To: | |
| References | |
| Download: ML25174A222 (1) | |
Text
ROP Data-Informed Inspection Concepts June 26, 2025 Rebecca Sigmon, NRR/DRO Alex Garmoe, NRR/DRO
Baseline Inspection Program
- Baseline inspection program provides indication of licensee performance in areas not measured or not fully measured by performance indicators
- Baseline inspections will
- 1) verify the accuracy of PI information provided to the NRC by licensees
- 2) provide indications of licensee performance in the inspectable areas
- 3) inspect the effectiveness of licensee PI&R programs
- Under the baseline inspection program, all areas where there is a need to inspect a licensees performance are defined as inspectable areas.
- With the ROP, inspections within these areas were adjusted where licensee performance to meet a cornerstone objective is adequately gauged by performance indicators.
Baseline Inspections IP 71151 IP 71152 Performance Indicator Verification Identification and Resolution of Problems Cornerstone-Based Inspections
- Inspection w/in Inspectable Areas
- Event Follow-up (IP 71153)
- Plant Status (IMC 2515 App. D)
Baseline Inspection Program
- Each inspectable area has a basis document, which describes the scope of the inspectable area and explains why the area is included in the baseline program. (See SECY-99-007.)
- Reasons for inclusion in the program may be that
- 1) the area is linked to the NRCs mission
- 2) the inspectable area involves a key attribute of a cornerstone of safety
- 3) risk information justifies including the area in the baseline inspection program
- Basis document for each inspectable area also identifies whether a performance indicator applies to the area and what inspections may be needed to supplement or complement the information provided by the performance indicators in the area
Inspectable Areas
- IMC 2515 Appendix A maps out inspectable areas by Cornerstone
Cornerstone Attributes IMC 2515 Appendix A also maps out how Cornerstone Attributes are covered by the ROP Cornerstone Cornerstone Attributes Inspectable Areas
The Goal of This Effort More Data More Inspection Less Inspection Less Data Today 2027 What do we need to make this shift in each inspectable area
With More Data
- Inspectable areas covered with more data and less, but better targeted, inspection effort
- Lower level data distinct from current concept of Performance Indicators PIs feed plant assessment and Action Matrix Lower-level data would inform baseline samples
- Potential resident inspector baseline:
Plant status activities and Corrective Action Program reviews Data verification Bank of flexible hours to apply based on plant status and data review Minimal-to-no required samples when an inspectable area is adequately covered by data Event follow-up (as needed)
Example 1: Attribute - Design
- What data can help assess the inspectable areas such that they no longer require mandatory samples ?
Count of Operator Workarounds?
Main Control Room deficiencies?
Count of entries into elevated risk conditions?
Unplanned entry into shutdown Limiting Conditions for Operations?
Surveillance failures?
Change in risk from temporary modifications?
Mitigating Systems Design Design Modifications Initial Design Inspectable Areas PI&R Operator Workarounds Evaluation of Changes System Design and Performance Temp. Modifications
Example 2:
Attribute - Equipment Performance Equipment Performance attribute of MS Cornerstone: Reliability and Availability
- Reliability:
Safety System Functional Failure and MS Performance Index PIs Inspectable areas: PI&R, Equipment Alignment, Maintenance Rule implementation, Operability Evaluations, Surveillance Testing
- Availability:
MSPI PI Inspectable areas: Maintenance Rule implementation These are inspected under:
71111.04 Equipment Alignment 71111.15 Operability Evaluations 71151 PI Verification 71111.12 Maintenance Effectiveness 71111.19 Post Maintenance Testing 71152 PI&R 71111.13 Maintenance Risk 71111.22 Surveillance Testing 71111.21M CETI
What Data Could Reduce Inspection?
Functional Failures Unavailability Component Mispositioning Events Human Error Events Work Order deferrals Unplanned short duration LCOs Functional Failures Unavailability Work Order deferrals CAP deferrals Unplanned short duration LCOs Unplanned downpowers Unplanned short duration LCOs Unplanned increase in plant risk condition Human Error Events Component Mispositioning Events IP 71111.04 Equipment Alignment IP 71111.12 Maintenance Effectiveness IP 71111.13 Maint Risk &
Emergent Work Control
Data Informs Need for Inspection Increasing instances of unplanned short duration LCO entries Consider samples:
71111.04 Equipment Alignment 71111.12 Maintenance Effectiveness 71111.13 Maint. Risk &
Emergent Work Control Increasing instances of work order deferrals Consider samples:
71111.04 Equipment Alignment 71111.12 Maintenance Effectiveness No min or max samples for most specific IPs Baseline Inspection Program =
Plant Status activities +
data-informed inspection There is min and max total baseline inspection hours, with max being set at some % less than now Note: this exercise was done only looking at the Availability and Reliability items of the Mitigating Systems Cornerstone attribute of Equipment Performance. When fully applied across all cornerstones, additional sample options would exist for many data elements.
The Goal of This Effort
- Review existing ROP Performance Indicators Determine whether to keep, revise, eliminate each Determine whether they continue to feed into Action Matrix
- Identify additional data sources that could be used as indicators of performance Do any feed into Action Matrix Do they inform baseline inspection effort
- Map indicators to inspection effort to inform what a future baseline inspection program could look like Reduced inspection in areas covered by additional data Adjust inspection focus with a modern risk-informed mindset Optimize the inspection effort that does occur based on data results
Questions and Discussion