ML19058A718
| ML19058A718 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/2019 |
| From: | Kenneth Kolaczyk NRC/NRR/DIRS/IRIB |
| To: | Thomas Hipschman NRC/NRR/DIRS/IRIB |
| Kolaczyk K, 315-342-4907, NRR/DIRS | |
| References | |
| Download: ML19058A718 (3) | |
Text
March 7, 2019 MEMORANDUM TO: Thomas R. Hipschman, Chief Reactor Inspection Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM: Kenneth S. Kolaczyk, Operations Engineer Reactor Inspection Branch /RA/
Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
SELF ASSESEMENT RESULTS FROM A REVIEW OF NUCLEAR REGULATORY COMMISSION INSPECTION PROCEDURE 95001 This memo provides summarizes the results of two self-assessments performed on the August 24, 2016, change to the Nuclear Regulatory Commission (NRC) Inspection Manual Chapter (IMC) procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. This procedure was revised in August 2016, to incorporate the direction contained in Staff Requirements Memorandum, SECY-15-0108 Recommendation to Revise the Definition of Degraded Cornerstone as used in the Reactor Oversight Process from approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to complete for one white issue and approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> to complete for two white issues.
Background
Over the past two years during working meetings, and in a September 19, 2018, letter to the NRC, the Nuclear Energy Institute (NEI) has questioned how the NRC has implemented the August 24, 2016, revision to Inspection Procedure (IP) 95001 and whether the inspection effort required by IP 95001 is warranted given industry performance. Further, NEI noted the inspection governance contained in IP 95001 does not mirror recent changes in licensee corrective action programs as described in TECHNICAL REPORT NEI 16-07, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency a draft of which NEI provided to the NRC for information only on May 31, 2017, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17152A242) and to which NRC provided observations on December 22, 2017, (ADAMS Accession No. ML17319A140).
CONTACT: Kenneth S. Kolaczyk, NRR/DIRS (301) 415-1169
T. Hipschman 2 Action In response to the NEI concerns regarding IP 95001, a cross Regional / Head Quarters task force was formed in December 2017. Before disbanding in April 2018, the task force determined that any implementation anomalies were not the result of the August 2016 procedure update, but were more likely the result of additional NRC focus on the need for licensees to increase the scope of their corrective actions and explore additional plausible causes for event occurrence as part of the corrective action process In September 2018, I performed another self-assessment review of IP 95001, as directed by you in several internal e-mail communications. I concluded in my review that the revised procedure and supporting changes to the NRC action matrix, had achieved their original goal of reducing unnecessary regulatory burden, as no plants had transitioned to Column 3 of the NRC action matrix following implementation of SECY-15-0108. Further, I concluded that similar to what the first task force had determined, any implementation anomalies regarding IP 95001, were not the result of the August 2016 procedure update but were more likely the result of additional NRC focus on the need for licensees to increase the scope of their corrective actions.
Therefore, no significant changes to the procedure or NRC inspector training programs were warranted. However, although I did not identify any substantive issues, the following procedure enhancements to IP 95001 were suggested for evaluation: (1) To enhance the dissemination of best practices among regions and improve consistency of the inspection process, consider the use of inspectors from other regions to perform IP 95001 inspections; (2) To align the procedure with current industry practices, remove the expectation that licensees conduct root cause evaluations to address issues that are being reviewed as part of a IP 95001 inspection; (3) To reflect the reality that some issues that are of White significance do not require significant follow-up, reduce inspection hours that are allocated to review a single white ROP Action Matrix issue. No other changes or enhancements to IP 95001 are recommended at this time.
On October 18, 2018, I briefed the results of this memo to Chris Miller, the Director of the Division of Inspection and Regional Support who agreed with my conclusions and recommended procedure enhancements. The revised IP 95001 is ready for your review and has been placed into ADAMs for consideration.
ML19058A718 *Concurred via email OFFICE NRR/DIRS/IRIB NAME KKolaczyk DATE 3/7/19