ML18072A061
| ML18072A061 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/2018 |
| From: | NRC/NRR/DIRS/IRIB |
| To: | |
| Agrawal A, NRR/DIRS, 415-8310 | |
| Shared Package | |
| ML18072A036 | List: |
| References | |
| Download: ML18072A061 (8) | |
Text
Enclosure 2 Reactor Oversight Process Presentation Material March 1, 201 8 Document Date: 12 March 2018 Upcoming Changes to Baseline Inspection Procedures to Address Aging Management Program EffectivenessMarch 2018William HolstonNRR DMLR
Background
Long-lived: structures and components (SCs) that are not periodically placed.Passive: SCs that perform their intended function without moving parts or a change in state.Aging management programs (AMPs): programs developed by licensees during the license renewal application process.
2 Inspection ProceduresIMC 2515, Light Water Reactor Inspection Program
-Operation Phase," Appendix D Plant StatusChange incorporates guidance on observing for indications of degradation of passive components during tours.IP 71111.12, Maintenance EffectivenessOne or two of the eight to ten maintenance effectiveness performance issues will be associated with AMP effectiveness.IP 71152, Problem Identification and ResolutionOne of the five to nine samples in the annual followupof selected issues will be associated with inspection results that did not meet acceptance criteria.
3 Inspection Procedures, cont.IP 71111.21M and IP 71111.21N Design Bases Assurance Inspection (Teams and Programs, respectively)One of the one to three operating experience examples will be related to AMP effectiveness.IP 71003, Post-ApprovalSite Inspection for License RenewalPhase IV inspections, determining whether a licensee is conducting adequate AMP effectiveness reviews, will be conducted in the 5
-10 year period upon entering the period of extended operation.IMC 2516 Policy and Guidance for the License Renewal Inspection ProgramGuidance will be added to describe how AMP effectiveness reviews will be conducted.
4 Implementation.
- Procedure changes are currently being developed.
- Anticipate completion of all procedure changes to occur in this fiscal year.
- As changes are developed and reviewed, the staff will provide further industry briefings.
5 Highlights of ROP / Fukushima Working Group Efforts
Background
A NRC working group was established on October 2, 2017 to consider how to integrate the results of regulatory actions
, taken by the NRC following the Fukushima D ai-ichi accident
, into the ROP (ML17164A285
). Multiple NRC offices, including all Regions, are represented. The goal is to begin implementation of any new ROP program documents by January 1, 2020.
The first milestone (March 31, 2018) is to develop final proposals (e.g. NRC management approval on proposal for inspection requirements, level of effort, resource estimates, etc.)
Highlights of Effort to Date The working group has completed review of FLEX and is tentatively recommending incorporation into the ROP as follows
- o Revise guidance in existing IPs to reiterate flexibility in sample selection of FLEX when utilized in risk
-significant conditions. (IP 71111.01, "Adverse Weather Protection
," IP 71111.13, "Maintenance Risk Assessments and Emergent Work Control
," IP 71111.15, "Operability Determinations and Functionality Assessments,"
and IP 71111.20, "Refueling and Other Outage Activities"
) o Expand scope requirements in existing IP to allow for flexibility in sample selection of FLEX when utilized in risk
-significant conditions. (I P 71111.22, "Surveillance Testing
") o Development of a new beyond design basis IP to be performed on a triennial (or longer) basis. Overall direct inspection effort would be around 8
-16 hours. IP would inspect defense in depth aspects of FL EX. Will need to coordinat e with Engineering Working Group to ensure coordination of regional based inspection resources.
Next Near-Term Efforts Continue working group efforts to consider aspects of hardened containment vents, SAMGs, multi-source dose assessment, and focused evaluations &
integrated assessments that may warrant oversight and potential IP revisions.
Continue to engage external stakeholders and NRC management to solicit feedback.
David Garmon, Health Physicist, NRR/DRA/ARCB david.garmon@nrc.gov , (301) 415-3512 Radiation Protection Cornerstones Discussion Points Reactor Oversight Process Monthly Public Meeting March 1, 2018 ADAMS Accession No. ML18059B183
- 1. Inspection Procedure Updates (notable changes) a. Removed individual PI&R samples for all IPs
- i. Generate consistency with other baseline procedure areas
- b. PI&R remains 10
-15% of inspection effort
- c. 71124.01 - Radiological Hazard Assessment and Exposure Controls
- i. Piloting new IP format by including programmatic information (e.g. samples, resource estimate etc.) on the first page ii. Move d 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from ALARA attachment
- i. Reduced avg biennial hours from 54 to 46 (+/- 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> depending on collective dose quartile performance)
- e. 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
- i. Added inspection requirement
-in response to an ROP feedback form
-directing inspectors to review radiation monitor threshold calculations for recently modified systems that are used as inputs to emergency action level (EAL) determinations.
- 2. Significance Determination Process Appendix C and D Update a. Currently resolving preliminary staff comments
- b. 30-day preliminary regional office review (March/April 2018)
- c. Public comment period (April/May 2018) i. Will be announced during ROP Monthly
- d. Commission approval (fall 2018/winter 2019)
- 3. Reinstatement of Health Physics Position Program (HPPOS
) via IMC a. Goal of completing this effort during the summer of 2018 b. Legacy HPPOS are currently available on the public website (https://www.nrc.gov/about
-nrc/radiation/protects
-you/hppos/hppos.html) c. Cataloging of staff positions for knowledge management purposes
- 4. Regulatory Guide Update
- a. RG 8.7, Rev 4, "Instructions for Recording and Reporting Occupational Radiation Exposure Data"
- i. Public comments being dispositioned with goal to get document into formal internal review in mid-March 2018 b. RG 1.8, Rev 4, "Qualification and Training of Personnel for Nuclear Power Plants"