ML18178A587

NEI Operability Public Meeting June 28, 2018 - Final

ML18178A587
Person / Time
Issue date:	06/28/2018
From:	Joseph Holonich NRC/NRR/DLP/PLPB
To:
Holonich J, NRR/DLP, 415-7297
References
Download: ML18178A587 (21)

Text

© NEI 2018. All rights reserved.

OPERABILITY PROCESS ENHANCEMENT &

NEI 18-03 NRC PUBLIC MEETING JUNE 28, 2018

© 2018 NEI. All rights reserved.

© NEI 2018. All rights reserved.

PURPOSE

- Engage with NRC to enhance the predictability and efficiency of the Operability Determination process.

- Inform the NRC on the process contained in NEI 18-03, Operability Determination

- Identify areas within Inspection Manual Chapter (IMC) 0326 for revision 2

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AGENDA

Background

Overview of the NEI 18-03 process Overview of crosswalk between IMC 0326 and NEI 18-03 Detailed discussion of six areas to gain predictability and efficiency

- Emphasizing that operability is the responsibility of the licensee

- Separating operability determinations from the Corrective Action Program (CAP)

- Defining common terms

- Establishing entry criteria

- Eliminating aspects not specifically tied to operability

- Ensuring operability is separate from ASME Code compliance Proposed engagement strategy and schedule 3

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BACKGROUND

• At 2015 RUG III meeting, NRC questioned why industry relies on IMC 0326 for guidance (unique practice)

• Engagement with NRC during process development

• Control room burden of applying current OD process frequently not commensurate with safety significance

• Recent, high-visibility plant issues illustrated challenges to predictability and efficiency of OD process 4

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NEI 18-03 OVERVIEW

• Clean sheet approach

- Use correct process tied to governing regulation and Technical Specifications (TS)

• If no process change, retained IMC 0326 concept/wording

• Guiding Principles

- Operability is a binary decision

- Operability is licensed operator responsibility

- OD is separate from CAP 5

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NEI 18-03 OVERVIEW

• Regulatory Basis

- Entry criteria

- Definitions

- Functionality

- ASME Code compliance 6

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NEI 18-03 HIGHLIGHTS Foundation is TS definition of operability Items will continue to be reviewed and assessed

- Questions are addressed via correct process Emphasis of revised process is on entry

- Confirmed impact on operability Degraded or Nonconforming condition concepts eliminated Immediate and Prompt OD - no change to existing process Defined specified safety function Consistent with IMC 0326, do not attempt to specify detailed actions when performing operability

- Engineering judgment acceptable 7

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COMPARISON TO IMC 0326

• Handouts provided in advance of meeting:

- Draft NEI 18-03

- Crosswalk/comparison between NEI 18-03 and IMC 0326 8

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SIX AREAS WHERE PREDICTABILITY AND EFFICIENCY CAN BE GAINED 9

Reference:

Letter from C. Earls to M. Gavrilas, Ensuring the Predictability and Efficiency of the Operability Determination Processes. May 22, 2018

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PREDICTABILITY AND EFFICIENCY

• Operability is the responsibility of the licensee

- Consistent with concepts in IMC 0326

- Senior Reactor Operators are licensed by NRC and are responsible for compliance with the Technical Specifications 10

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PREDICTABILITY AND EFFICIENCY

• Operability process is separate from CAP

- NEI 18-03 focus is on the definition of operability in the TS

• Operability decision is binary

- CAP focuses station resources on restoration of the deficient condition 11

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PREDICTABILITY AND EFFICIENCY

• Eliminating aspects not specifically tied to operability

- Degraded and non-conforming condition classifications and functionality eliminated

• No regulatory basis

• Related to corrective action, not operability

• Distraction to the binary determination of operability

• Defining common terms

- Specified Safety Function defined

• Detailed derivation in Appendix B of NEI 18-03 12

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SPECIFIED SAFETY FUNCTIONS 13 10 CFR 50.36(c)(2)(ii) requires an LCO be established on an SSC if it meets one of the criteria.

CRITERIA = LCO A TS LCO requires an SSC to be operable, equating LCO compliance with SSC operability.

LCO = OPERABILITY The TS definition of operability states that an operable SSC must be capable of performing its specified safety functions, equating operability with specified safety functions.

OPERABILITY = SSF Therefore, the regulations and the TS establish a link between the criteria in 10 CFR 50.36(c)(2)(ii) and the specified safety functions of an SSC.

CRITERIA = LCO = OPERABILITY = SPECIFIED SAFETY FUNCTIONS

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PREDICTABILITY AND EFFICIENCY

• Establishing entry criteria 1.

The deficient condition must affect a TS SSC installed in an operating unit.

2.

The deficient condition must have a functional impact on the SSC. This includes the ability to perform required functions under postulated, off-normal design conditions.

3.

The functional impact of the deficient condition must be substantive (i.e., non-trivial).

• All three conditions must be met for immediate OD to be required

- SRO retains discretion to enter OD process at any time 14

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PREDICTABILITY AND EFFICIENCY Ensuring operability is separate from ASME Code compliance

- References to Code compliance in IMC 0326 not generally included in NEI 18-03

- Determination of operability is separate from Code compliance

- Any technically acceptable method can be used to determine if a specified safety function can be met (alternate methods)

- Licensed operator decision -NRC approval not required if technically defensible method used to determine operability

- Restoration of Code compliance is governed by CAP and 10 CFR 50.55a 15

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PROPOSED ENGAGEMENT STRATEGY AND SCHEDULE 16

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STRATEGY Apply lessons learned from successful and expedient engineering inspection streamlining effort

- NRC team composed of senior executive sponsor and headquarters and regional branch chiefs

- Industry team composed of regulatory and operations leaders empowered to make timely decisions

- Meeting locations include Rockville and regional offices to encourage inspector participation and awareness

- Meetings address distinct, specific technical issues

- Industry and NRC alternate who is in listening mode Scaled to align with impact of proposed change to operability 17

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SCHEDULE (2018)

June Public meeting - Overview of NEI 18-03 July No meeting - NRC reads NEI 18-03 and aligns internally on understanding and concerns August Public meeting - NEI introduction of entry criteria September Public meeting - NRC feedback on entry criteria October Public meeting - NEI introduction of OD/CAP interface, definitions, and items eliminated from OD November No meeting December Public meeting - NRC feedback on OD/CAP interface, definitions, and items eliminated from OD 18

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SCHEDULE (2019)

January Public meeting - NEI introduction of Code compliance changes February Public meeting - NRC feedback on Code compliance changes March No meeting - Ongoing work featured in panel discussion at Regulatory Information Conference April Public meeting - Finalize discussions, determine path forward (i.e. revision to NEI 18-03 and IMC 0326)

May No meeting - NEI incorporates feedback and transmits final NEI 18-03, NRC begins work on IMC 0326 revision June Final public meeting on OD 19

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SUMMARY

• Licensee continues to own operability

- Industry developed its own guidance to do so

• Limited changes to existing process

• No change to continuously assessing operability

• Adding predictable entry criteria

• Aligning to other plant processes to improve efficiency 20

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QUESTIONS / DISCUSSION 21