ML19107A491

Proposal to Modify Treatment of Greater than Green Performance Indicators Presentation 04/24/2019

ML19107A491
Person / Time
Issue date:	04/24/2019
From:	Alex Garmoe NRC/NRR/DIRS/IRAB
To:
Garmoe A
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Download: ML19107A491 (25)

Text

Proposal to Modify Treatment of Greater than Green Performance IndicatorsROP Public MeetingApril 24, 2019

Background

• ROP enhancement recommendation 2B.5

-prompt closure of White findings

• Adopting the recommendation would:

-Encourage prompt evaluation, correction, and independent verification via inspection

-Potentially impair aggregation of White findings

-one of the ways ROP detects declining performance

• Overall staff believes the recommendation benefits safety and recommends adoption

• Staff noted that this benefit did not extend to the manner in which GTG PIs are treated; explored whether GTG PI treatment should be modified 2

Current Treatment of GTG PIsWhite inputColumn 2Parallel FindingWhen PI becomes White

• White assessment input

• Action Matrix Column 2

• Supplemental inspection scheduledPI might return to Green before supp. inspection

• No longer a White assessment input, even if no corrective actions taken or no supplemental inspection

• Action Matrix Column 2Supplemental inspection

• Close issue or keep open

• If PI has returned to Green but issue not closed, parallel White finding is opened.*Parallel White finding backdated to when PI returned to GreenColumn 2All Green 3 Current Treatment of PIs Example

• Unplanned scrams PI White in 3Q2016 and 4Q2016, returned to Green in 1Q2017

• Plant moved to Column 2 and remains in Column 2 pending supplemental inspection, even with all Green inputs 4

Current Treatment of PIs Example

• Notification of readiness for inspection received in June 2017*Inspection conducted in August 2017

-Identified significant weaknesses in causal evaluations for scrams in March and June 2016

-Parallel White finding issued in 4Q2017 and backdated to 1Q2017 (when PI returned Green)

• Parallel finding closed by inspection in 2Q20182Q20163Q20164Q20161Q20172Q20173Q20174Q20171Q20182Q2018Unplanned Scrams PIParallel White opened back to 1Q2017 95001 completed 6/28/18Scrams PI parallel white findingN/AN/AN/Aparallel WhiteAction Matrix ColumnColumn 1Column 2Column 2Column 2Column 2Column 2Column 2Column 2Column 2Assessment InputsAll Green1 White1 WhiteAll Green revised to 1 WhiteAll Green revised to 1 WhiteAll Green revised to 1 White1 White1 White1 White 5 Historical Data Review

• Excluded Yellow and Red Findings and PIs

• Excluded White inputs encompassed in 95002 or 95003 inspections

• Could not locate licensee readiness dates for some inspections, particularly early in ROP

-These inspections not included in timing data 6

Historical Data Review

• Focus on common part of process

-after GTG finding issued or PI submitted

• White PI start time: first day of quarter in which White PI reported-Ex: By 1/21/15 a 4Q2014 White PI is submitted. Start date assumed to be 1/1/15.

• White finding start time: date of issuance of final significance

• This is the point in both processes when it is known that a supplemental inspection will occurWhite FindingsSignificance determinationWhite PIsVarious PI occurrencesPrepare for IP 95001 inspection and notify NRC of readinessNRC schedules and conducts IP 95001T=0 7 Historical Data ReviewWhite FindingsWhite PIsTimefor supplemental inspection readiness127 days average(2% greater than 1 year)(7% greater than 3 quarters)202 days average(9% greater than 1 year)(26% greater than 3 quarters)Time for agency to complete supplemental inspection66 days71 daysWhite FindingsSignificance determinationWhite PIsVarious PI occurrences127 days66 days202 days71 days 8 Historical Data Review

• Time until readiness for White PIs has been increasing while decreasing for White findings 9

Historical Data Review

• Similar trend observed in overall timelines from finding start date/PI submittal to completed supplemental inspection 10 Data Conclusions

• Licensees taking more time to prepare for supplemental inspections for PIs than Findings

• The "readiness gap" is widening 11 Data Conclusions

• Increase in time for readiness of inspection of White PIs despite White PIs shifting into IE cornerstone

• IE cornerstone PIs involve discrete events that are individually evaluated when they occur, which would seem to streamline supplemental inspection preparation 12 Data Conclusions

• PIs are data driven so staff does not believe increased time is due to disagreement with characterization of the issue

• Does not appear to be due to IP 95001 scope concerns since the readiness trend (and overall timeline trend) for GTG findings is decreasing

• The four quarter requirement for GTG findings may be a reason for the trend toward quicker readiness for GTG finding supplemental inspections 13 Data Conclusions 14 Proposed Treatment of GTG PIsWhen PI becomes White

• White parallel finding isopened and is the assessment input

• Action Matrix Column 2

• Supplemental inspection scheduled when licensee is readyPI data reported as usual

• PIdata might return to Green or stay GTG

• Either way the parallel finding is tracking the issue that must be inspectedSupplemental inspection

• Either closes the parallel finding or keeps it open

• If closed, plant moves to Column 1 even if PI hits haven't rolled off PI calculation yetParallel FindingColumn 2Column 1Parallel Finding closed by inspection 15 Proposed Treatment of GTG PIs

• Benefits of proposed approach:

-Encourages prompt correction and inspection of issues*PI hits can be removed once inspection closes the parallel finding

• Action Matrix movement upon inspection completion

-Elimination of backdated parallel findings

• Enhances regulatory certainty

• More timely and stable assessment results 16 Proposed Treatment of GTG PIs Example 1

• Revisiting the unplanned scrams GTG PI example2Q20163Q20164Q20161Q20172Q20173Q20174Q20171Q20182Q2018Unplanned Scrams PIParallel White opened back to 1Q2017 95001 completed 6/28/18Scrams PI parallel white findingN/AN/AN/Aparallel WhiteAction Matrix ColumnColumn 1Column 2Column 2Column 2Column 2Column 2Column 2Column 2Column 2Assessment InputsAll Green1 White1 WhiteAll Green revised to 1 WhiteAll Green revised to 1 WhiteAll Green revised to 1 White1 White1 White1 White2Q20163Q20164Q20161Q20172Q20173Q20174Q20171Q20182Q2018Unplanned Scrams PIParallel finding opened 95001 completed 6/28/18Action Matrix ColumnColumn 1Column 2Column 2Column 2Column 2Column 2Column 2Column 2Column 2Assessment InputsAll Green1 White1 White1 White1 White1 White1 White1 White1 White 17 Proposed Treatment of GTG PIs Example 2

• Assume PI went White in 4Q2017 due to scrams in 1Q2017 and 4Q2017

• 2 additional scrams in 2Q2018 18 Proposed Treatment of GTG PIs Example 2

• After going White in 4Q2017 the PI returned to Green in 1Q2018

• Two additional scrams in 2Q2018 drove the PI White again

-Supplemental inspection had not been scheduled yet*Supplemental inspection completed in December 2018 and plant moved to Column 1 19 Proposed Treatment of GTG PIs Example 2

• Existing process provided little incentive for prompt evaluation and readiness for supplemental inspection, until the two additional scrams drove the PI White again

• Under the proposal, had a supplemental inspection closed the White PI issue before the end of 2Q2018, the new PI hits would not have resulted in a White PI in 3Q2018 20 Proposed Treatment of GTG PIs 21 Conclusion

• Staff believes current treatment of GTG PIs should be enhanced

-Process does not encourage prompt evaluation, correction, and inspection

-Regulatory uncertainty due to backdating of parallel findings-Delayed performance assessment

-Data review shows that readiness for PI supplemental inspections lags supplemental inspections for findings 22 ConclusionGTG FindingGTG PIWhitefinding issued, plant moves to Column 2White PI reported, parallel finding opened and plant moves to Column 2White finding remains open assessment inputuntil supplemental inspection completedParallel finding remains open assessment inputuntil supplemental inspection completedCorrective actions completedCorrective actions completed, PI might return to GreenSupplemental inspection completed

• Findingis closed and removed from assessment process

• Finding cannot be closed and remains open until future inspectionSupplemental inspection completed

• Finding is closed and removed from assessment process, PI hits removed

• Finding cannot be closed andremains open until future inspection 23 Next Steps

• Commission paper votes:

-Proposal to modify closure of GTG findings to supplemental inspection completion

-Proposal to modify treatment of GTG PIs

• Staff recommending that both changes be adopted*If approved, would engage with industry on guidance revisions to accommodate removal of PI hits once inspected and closed 24 Questions