ML21182A110
| ML21182A110 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/2021 |
| From: | Thomas Hipschman NRC/NRR/DRO/IRIB |
| To: | Mike Franovich, Chris Miller NRC/NRR/DRO |
| References | |
| Download: ML21182A110 (13) | |
Text
.
July 30, 2021 MEMORANDUM TO: Christopher G. Miller, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation Michael X. Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation FROM: Thomas R. Hipschman, Chief /RA/
Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
WORKING GROUP TO ENHANCE INSPECTION PROCEDURE 37060, 10 CFR 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION The purpose of this memorandum is to communicate the results and recommendations from the Working Group to Enhance Inspection Procedure (IP) 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components. The working group was formed in October of 2020 and included representatives from all four regions and the headquarters office. The objective of the working group was to identify recommendations and implement management decisions associated with the enhancement of IP 37060.
CONTACTS: Jeff Bream, NRR/DRO/IRIB John Hughey, NRR/DRA/APOB 610-337-5212 301-415-3204
C. Miller and M. Franovich 2 The working group identified several potential enhancements to the existing IP 37060 and opportunities to enhance inspector training. These recommendations are discussed in the enclosure.
Enclosure:
As stated,
C. Miller and M. Franovich 3
SUBJECT:
WORKING GROUP TO ENHANCE INSPECTION PROCEDURE 37060, 10 CFR 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION DATED: July 30, 2021 DISTRIBUTION:
RidsRgn1MailCenter Resource RidsRgn2MailCenter Resource RidsRgn3MailCenter Resource RidsRgn4MailCenter Resource RidsNrrDra Resource RidsNrrDroIrib Resource ADAMS Accession Number: ML21182A110 NRR-106 OFFICE NRR/DRO/IRIB NRR/DRA/APOB NRR/DRO/IRIB NAME JBream JHughey THipschman DATE 7/06/2021 7/7/2021 7/30/2021 OFFICE NRR/DRA/APOB RI/DORS NRR/DRO CMiller (for KMorgan-NAME AZoulis PKrohn Butler)
DATE 7/12/2021 7/16/2021 7/29/2021 OFFICE NRR/DRA NAME MFranovich DATE 7/29/2021 OFFICIAL RECORD COPY
RECOMMENDATIONS FROM WORKING GROUP TO ENHANCE INSPECTION PROCEDURE 37060, 10 CFR 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION
- 1.
Background:
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, became effective on December 22, 2004 (69 Federal Register (FR) 68008). The US Nuclear Regulatory Commission (NRC) regulations in 10 CFR 50.69 allows an alternative approach for establishing the requirements for treatment of structures, systems, and components (SSCs) for nuclear power reactors using a risk-informed method of categorizing SSCs according to their safety significance. To date, nearly 40% of power reactor sites either have received a license amendment to implement the provisions of 10 CFR 50.69 or have a license amendment request under NRC review to allow them to implement 10 CFR 50.69.
IP 37060 was initially issued in September 2011 as a procedure under IMC 2515, Appendix C, Special and Infrequently Performed Inspections, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20321A277) and has not been significantly revised since its issuance. To date, IP 37060 has only been performed at Vogtle Electric Generating Plant, Units 1 and 2, in June 2016 (ADAMS Accession No. ML16223A738) and at Limerick Generating Station in February 2020 (ADAMS Accession No. ML20073H282).
Following the performance of the Limerick IP 37060 inspection, Region I prepared an Inspection Feedback, Lessons Learned, and Best Practices memorandum (ADAMS Accession No. ML20125A143) that proposed several potential enhancements to IP 37060 that could improve the performance of future licensee 50.69 program and implementation inspections. The memorandum recommended several actions including the following:
- Evaluate the sequence and timing of the inspection;
- Consider providing additional guidance in several areas including reportability requirements and passive risk categorization;
- Expand inspection areas to include additional focus areas (i.e. Problem Identification and Resolution);
- Provide additional guidance in specific areas concerning rule implementation;
- Recommendations for team experience and training; and
- Recommendations for additional inspector preparation resources.
A working group was formed to review and expand the recommendations from the Region I memorandum and experiences gained from the earlier pilot inspection conducted at the Vogtle Electric Generating Plant in June 2016. The working group consisted of representatives from each region, the Office of Nuclear Reactor Regulation (NRR) Division of Reactor Oversight (DRO), the NRR Division of Risk Assessment (DRA), and the NRR Division of Engineering and External Hazards (DEX). The working group charter can be found at ADAMS Accession No. ML20182A687. The working group comprised of the following individuals:
Paul Krohn (Executive Sponsor) Deputy Director, Region I/Division of Operating Reactor Safety (DORS)
Jeffrey Bream (Team Lead) Reactor Operations Engineer, NRR/DRO John Hughey Reliability and Risk Analyst, NRR/DRA Enclosure
Eugene DiPaolo Senior Reactor Inspector, Region I/DORS Shane Sandal Senior Reactor Analyst, Region II/DRS John Bozga Senior Reactor Inspector, Region III/Division of Reactor Safety (DRS)
Rick Deese Senior Reactor Analyst, Region IV/DRS Amar Patel Senior Reactor Inspector, Region I/DORS Andrew Rosebrook Senior Reactor Analyst, Region II/DRS Chris Safouri Senior Resident Inspector, Vogtle John Hanna Senior Reactor Analyst, Region III/DRS Kenneth Kolaczyk Reactor Operations Engineer, NRR/DRO Jigar Patel Reliability and Risk Analyst, NRR/DRA Johnathan Evans Reliability and Risk Analyst, NRR/DRA Thomas Scarbrough Senior Mechanical Engineer, NRR/DEX
- 2. Recommendations:
In accordance with the Be riskSMART framework, the working group developed the following recommendations for enhancement of IP 37060, inspector training, and inspector resources based on inspector and subject matter expert input.
Recommendations for Inspection Procedure Effectiveness Beclear about the problem:
Problem: Recent performance of an IP 37060 inspection by Region I inspectors identified difficulties with implementation of specific inspection requirements and gaps in guidance that could hinder inspector efficiency and inspection effectiveness.
Should NRR initiate a revision to IP 37060 at this time based on the feedback provided by the Limerick inspection team and evaluated by the working group?
Spotwhat can go right or wrong and the consequences:
What can go right: A comprehensive revision of IP 37060 will close the identified gaps in procedure guidance and training of inspection staff. Inspectors will be better trained and prepared for future inspections of licensee 10 CFR 50.69 programs. This will increase the effectiveness of the 10 CFR 50.69 inspections going forward and is especially important as the industry continues to implement risk-informed initiatives. The NRC will have reasonable confidence that licensees have correctly classified systems in accordance with the rule requirements.
What can go wrong: The comprehensive revision of IP 37060 might not result in significant efficiency gains. As a result, future implementation of IP 37060 will be no better than the current iteration.
Additionally, licensee implementation of 10 CFR 50.69 programs might not follow a format that would easily lend itself to inspection through the revised IP 37060 (e.g., licensees might only partially implement 10 CFR 50.69 for a limited number of site systems). As a result, performance of an IP 37060 inspection would be difficult or inefficient resulting in a shift of inspection burden to the baseline through existing guidance contained in baseline IPs and 2
without the benefit of the comprehensive inspection of the 10 CFR 50.69 program and implementation performed by IP 37060.
Finally, significant changes to the existing IP 37060 can cause potential unintended consequences that cannot be anticipated at this time.
Managewhat you can:
In order to address the problem statement and manage the potential positive and negative consequences, the following recommendations were identified.
Recommendation 1: Revise IP 37060 to the current inspection procedure template format as described in IMC 0040 to clarify what is an inspection requirement and what is inspection guidance.
Manage: Implementation of this recommendation will enhance the procedure by clarifying the inspection requirements and guidance and will assist inspectors in tracking inspection requirement completion during performance. This will directly address feedback from the Limerick and Vogtle inspections by clarifying inspection requirements. Additionally, opening the procedure for revision provides an opportunity to include additional enhancements to improve inspection efficiency and effectiveness.
If approved, staff would complete this revision by the 4th quarter of 2021. Multiple inspections are currently scheduled for calendar year 2022. A timely revision of IP 37060 would provide increased efficiency for the regions and align with the Principles of Good Regulation by providing opportunities for timely licensee preparation.
Level of Effort: Low to Medium Benefit: Low to Medium Recommendation 2: Schedule the performance of an effectiveness review for monitoring licensee implementation of 10 CFR 50.69 programs, assess the effectiveness of the implementation of the approved and implemented recommendations, and assess if additional changes to IP 37060 are needed.
Manage: In an effort to manage the potential consequences of what can go wrong, the working group recommends that IRIB schedule an effectiveness review of any and all changes made as a result of the recommended procedure revision. This effectiveness review should be performed in the second half of 2022 or the first half of 2023 depending on the number of completed IP 37060 inspections after the revision is issued. If no significant procedure revision is made, the IRIB effectiveness review will focus on inspection implementation and collection of lessons learned.
Additionally, guidance will be added to the inspection procedure recommending that the team lead provide any feedback or lessons learned through the performance of the inspection procedure to the program office. The direct and timely feedback from those performing the inspection will aid the performance of the effectiveness review and will assist the identification of issues and concerns in a timely manner.
Level of Effort: Low to Medium Benefit: Medium 3
Recommendations for Inspection Procedure Revision Beclear about the problem:
The following recommendations are linked to Recommendation 1 above. If a decision is made to revise IP 37060, the additional inclusion of these recommendations should be assessed.
The working group, consisting of subject matter experts in headquarters and the regions, have assessed the identified best practices and lessons learned from the Limerick IP 37060 inspection and identified enhancements to the IP that could aid future inspections.
Problem: Multiple options are available for addition or modification of IP 37060 if the decision to initiate a revision is made. Some options will require greater levels of effort and coordination between NRR and Regional stakeholders.
Which of the following recommendations should the working group implement as part of the revision to IP 37060? Which recommendations are the priority, and which can be tabled until a later time?
Spotwhat can go right or wrong and the consequences:
Each individual recommendation carries separate risks and benefits. These are addressed with each recommendation.
Managewhat you can:
Actions to address the potential risks and enhance the particular benefit of each recommendation are addressed individually for each recommendation.
Recommendation 3: Separate the inspection requirements for the licensee Feedback and Process Adjustments into a new section that can be performed at a later date.
Adjust the procedure completion requirements to clarify that the IP 37060 inspections can be performed in separate phases and that not all sections need to be completed for the procedure to be considered complete. Other inspection areas, such as health physics (IP 71124) and security (IP 71130), use a similar approach.
What can go right: An inspection requirement that is difficult to time and coordinate with the licensee can be moved to an independent section of the inspection procedure that can be performed at a later time. Additionally, the inspection does not need to be left open and tracked until that later time, eliminating a potential logistics challenge.
What can go wrong: Clarity and consistency of the inspection could suffer in that during scheduling with licensees, there might be confusion regarding which parts of IP 37060 are going to be performed and when. Separating the IP into phases may result in unnecessary resources and additional burden expended by the Region and Licensees.
Manage: A lesson learned from the Limerick IP 37060 inspection noted, at the time of the inspection, that licensee 10 CFR 50.69 feedback and process adjustment programs were not sufficiently developed compared to the implementation of the categorization and alternate treatment programs. This was not unexpected since, by regulation and program design, 4
licensee feedback and process adjustment programs might not be performed until, at most, two refueling outages after system categorization. This lag in the implementation of this aspect of the 10 CFR 50.69 rule resulted in difficulties in the completion of this inspection element during the Limerick IP 37060 inspection.
To address this inspection procedure deficiency, the working group recommends separating the feedback and process adjustment inspection requirement into a new section of the procedure that can be performed at a later date when an appropriate sample is available for inspection.
Additionally, based on the working groups recognition of the lag in licensee performance between 10 CFR 50.69 program implementation and the feedback and process adjustment program, the working group recommends that additional guidance be added to the Procedure Completion section to clarify that the IP 37060 inspection should be performed in separate phases. The first phase of the inspection should be completed after the licensee has categorized a sufficient number of systems such that an appropriate risk-informed sample of 3 to 5 systems can be selected for review. The second phase should be completed after sufficient time has passed following system categorization such that an appropriate risk-informed sample of 3 to 5 systems can be selected from the systems that have been assessed through the licensees feedback and process adjustment program (i.e., after two refueling outages).
To account for the potential significant time gap between the separate phases of the IP 37060 inspection and to simplify regional tracking of inspection issues, the working group recommends that each phase be considered a separate inspection activity. Completion of each phase will close that specific inspection. Furthermore, completion of the first phase will not necessarily mandate the completion of the second. Consideration may be given to allow the Feedback and Process Adjustment portion of the inspection to be conducted by the resident staff and not necessarily require an additional inspection team. In accordance with the requirements of IMC 2515, Appendix C, the performance of each phase of the IP 37060 inspection will be subject to Regional Administrator review and approval. Consistent with similar processes in the Health Physics and Security area, the sections of IP 37060 will be implemented during a specific 10 CFR 50.69 inspection and will be communicated to licensees as part of the annual assessment program.
Level of Effort: Medium Benefit: Medium Recommendation 4: Add inspection requirements to IP 37060 to close gaps that were identified in the performance of the 10 CFR 50.69 inspections at Vogtle and Limerick.
Specifically, add an inspection requirement to: (1) validate that license conditions (including updates to the PRA model, pending NRC alignment on an overall strategy for oversight of PRA configuration control) from the NRC license amendment are properly incorporated into licensee procedures and programs; and (2) verify that common cause reviews are performed for actual and potential deficiencies for RISC-3 (safety-related low-risk) components.
What can go right: The inspection procedure will direct inspectors to validate that all aspects of the approved license condition are added to the licensee implementing procedures.
Additionally, inspectors will be provided with direction to validate that licensees have performed common cause reviews for RISC-3 component deficiencies such that risks are identified and assessed prior to events that could invalidate the licensees SSC categorization process.
5
What can go wrong: The inspection requirements will be repetitive or duplicative to inspection requirements already contained in this or other inspection procedures.
Additionally, the inclusion of new inspection requirements could be met with objections from licensees that the new inspection requirements might not reflect regulatory requirements and could lead to an unnecessary burden.
Finally, if not coordinated properly with the NRC strategy for oversight of a licensees PRA configuration control, the revised inspection requirements may contradict or conflict with other NRC guidance.
Manage: During a review of IP 37060 by the working group, it was identified that while several inspection requirements verified that licensee procedures reflected programs and processes as described in the license amendment request and supporting NRC safety evaluation, there were no inspection requirements to verify that any additional conditions set by the NRC in the license amendment were also incorporated into licensee programs, policies, and procedures. This recommendation to add this requirement into IP 37060 will close this gap and verify that licensee implementation of their 10 CFR 50.69 program is in accordance with requirements.
Additionally, the working group identified that there was no inspection requirement to verify licensees are appropriately evaluating actual and potential deficiencies associated with RISC-3 components for common-cause failure. It was recognized by the working group that alternate treatment of RISC-3 components presents an opportunity for common cause deficiencies to impact the overall assumptions made in the categorization process. The addition of this inspection element will direct inspectors to perform a sample evaluation of RISC-3 components for potential and actual common-cause deficiencies to verify that the licensee has adequately considered common-cause interaction susceptibility in similar components with similar alternate treatment.
Through the involvement of subject matter experts and a review of the 10 CFR 50.69 final rule Federal Register Notice, the working group concluded that there is sufficient regulatory basis for the aforementioned additional RISK-3 inspection requirements. Specifically, the Federal Register Notice for the final rule states, in part, the inspection will also consider the implementation of RISC-3 treatment focusing on programmatic and common cause issues, which could undermine the categorization process and its results.
Level of Effort: Low Benefit: Medium Recommendation 5: Add a review of the licensee problem identification and resolution (PI&R) program to the inspection procedure, similar to how it is included in baseline Reactor Oversight Program (ROP) inspections.
What can go right: The inspection procedure will provide specific direction and guidance for the inspection of the licensee PI&R program relative to 10 CFR 50.69 implementation and align IP 37060 so that it is consistent with other inspection procedures.
What can go wrong: Implementation of 10 CFR 50.69 allows for 10 CFR Part 50, Appendix B, requirements to be removed for RISC-3 components. Therefore, there might be concerns raised by licensees regarding the need for the NRC to inspect this area. However, corrective action requirements are included in a separate 10 CFR 50.69 requirement. Lack of clarity of 6
what is applicable and what is exempt could cause confusion for inspectors implementing this inspection requirement.
Manage: The working group identified that there is currently no explicit review of the licensees PI&R program for entries associated with the implementation, categorization, and alternate treatment of components within the 10 CFR 50.69 program similar to how baseline ROP inspections review the licensees PI&R program. This causes difficulties in assessing the adequacy of various inspection requirements associated with the implementation of the 10 CFR 50.69 rule and can lead to inconsistent inspection results based on inspector experience.
Addition of this inspection requirement is consistent with other baseline ROP inspections. The overall resource expenditure for this requirement would not add to the current resource estimate of the procedure.
Level of Effort: Low Benefit: Low Recommendation 6: Revise guidance for inspection team composition to increase flexibility if Senior Reactor Analyst (SRA) support is limited. However, a recommendation is included that the site resident or senior resident inspector participate in the IP 37060 inspection as a team member.
What can go right: Increase regional flexibility in inspection staffing related to SRA position and enhance relevant plant knowledge and experience of team.
What can go wrong: SRA not actively participating in the team could impact efficiency and effectiveness of the inspection of PRA related aspects of licensee 10 CFR 50.69 implementation. Adding the expectation that a current resident or senior resident participate as a team member could decrease overall regional flexibility in inspection staffing.
Manage: The working group identified that the current recommendations of team composition were too prescriptive in relation to the participation of a regional SRA on the team. While it is recognized that the review and verification of the licensees PRA requires specific and specialized knowledge possessed by the regional SRAs, other regional personnel may also possess similar training and background without the SRA title. Accordingly, the working group recommends revising the inspection team composition guidance to clarify that a qualified inspector with similar training and background can serve the same function as long as the regional SRA is available for support, if needed.
In conjunction with the recommendation to increase flexibility with respect to regional SRA participation, the working group endorses adding guidance that the current resident or senior resident for the site participate in the inspection team. Alternatively, guidance should be added for regions to consider personnel with a similar level of familiarity with the site as the resident and senior resident. This recommendation is based on lessons learned from the Limerick IP 37060 inspection that the site-specific experience of the resident inspector (an assigned team member) was invaluable to the teams ability to successfully complete the inspection.
Additional guidance for consideration would also be included for the regions to consider cross-regional inspector participation. This would especially be valuable in instances where inspectors experienced in 10 CFR 50.69 inspections could support those regions that have limited direct experience.
7
Level of Effort: Low Benefit: Medium to High Recommendation 7: Add a public and non-public resource list to the inspection procedure that contains links to appropriate resources and training.
What can go right: A centralized repository of inspection guidance and resources would aid the inspection team in preparing and performing the IP 37060 inspection.
What can go wrong: Curation of the resource list could lag current guidance and best practices resulting in limited value.
Manage: The working group has identified that there are a significant number of existing internal and external resources available to the inspection staff to assist in training, preparation, and performance of IP 37060. The resources include internal training presentations, industry and NRC guidance documents, a sample document request list, a sample inspection plan, and NRC points of contact. The working group recommends that these resources be consolidated and added to IP 37060 for future inspector use. However, the working group recognizes that many of these resources may change over time as guidance evolves and future lessons learned are identified. Because of the potential for resources to be added, deleted, or revised, the working group recommends that the resource list be maintained in a non-public ADAMS document or Nuclepedia pagethat can be revised more readily than IP 37060 itself.
Applicable publicly available resources will be added to the IP for use and reference by internal and external stakeholders.
Level of Effort: Medium Benefit: Medium Recommendations for Inspector Training and Resources Beclear about the problem:
The following recommendations are not directly related to a revision of IP 37060. These additional recommendations were identified by the working group as a means to further improve baseline inspection, inspector training, and inspection preparation.
Problem: Other potential gaps in inspector guidance and training were identified by the working group.
Should the working group engage in efforts to enhance 10 CFR 50.69 inspection guidance that is contained in other inspection procedures including: enhancing inspection guidance of 10 CFR 50.69 in the existing baseline inspection program; enhancing 10 CFR 50.69 inspector training; and providing guidance for the assessment of inspector findings of deficient licensee performance?
Spotwhat can go right or wrong and the consequences:
What can go right: Improving inspection guidance and training can help close knowledge gaps for inspectors and enhance regional consistency. Many inspectors currently have limited experience with 10 CFR 50.69 rule implementation; however, multiple licensees have submitted license amendments to adopt the rule.
8
What can go wrong: The working groups activities in this area may be redundant to existing efforts and programs that are designed to improve the quality of inspector training resulting in an inefficient use on NRC resources as the working groups scope growth expands beyond what was originally intended.
Managewhat you can:
The working group identified additional recommendations associated with licensee 10 CFR 50.69 program implementation and inspector training. However, these recommendations are not directly associated with IP 37060.
In order to address the problem statement and manage the potential positive and negative consequences, the following recommendations were identified.
Recommendation 8: Enhance guidance in baseline inspection procedures for appropriate areas to inspect within the baseline. For example, include a potential sample in IP 71111.12 guidance to review the Feedback and Process Adjustments program for individual systems.
Manage: Baseline IP 71111.12 currently contains guidance for selection of samples related to licensee implementation of 10 CFR 50.69. The working group recommends enhancing guidance for residents to select, if available and appropriate, the inspection of licensee implementation of the feedback and process adjustment program for individual systems separate from the one-time multi-system review performed using IP 37060.
Level of Effort: Low Benefit: Medium Recommendation 9: Coordinate with OCHCO and NRR to develop additional inspector training on 10 CFR 50.69, industry documents, and approved methodologies. The developed training should update the current general 10 CFR 50.69 rule overview training module and create a new training module on passive component categorization. This training would be placed in TMS and would be available for use prior to conduct of a 10 CFR 50.69 inspection activity.
Manage: Through the review of available resources, the working group identified multiple training presentations that have been provided to the staff since the rule was published and IP 37060 was developed. The working group recognized that some of the guidance in the presentations has been revised. Additionally, the working group identified that passive component categorization, which is a difficult and specialized topic in 10 CFR 50.69 component categorization, was not part of any of the recent training presentations.
T. Scarbrough and J. Hughey presented overview training in August 2020 for NRR technical reviewers on the implementation of 10 CFR 50.69 at nuclear power plants following NRC acceptance of license amendment requests submitted by licensees. The overview training included a summary of specific technical topics that can be addressed in future training. The specific topic training can also discuss technical areas of interest to the Region inspectors.
Level of Effort: Low Benefit: High Recommendation 10: Generate appropriate examples of minor and more-than-minor inspection findings for inspector reference. This information will be included in the updated general 10 CFR 50.69 rule overview training module and IMC 0612 Appendix E.
9
The working group recognizes that inspectors will develop observations and potential findings associated with licensee implementation of 10 CFR 50.69 programs. The working group recommends that examples of findings, including minor and more than minor screening, be generated to assist inspector assessment of potential findings.
Level of Effort: High Benefit: Low Recommendation 11: Enhance guidance related to 10 CFR 50.69 reportability requirements.
The working group recognizes that there is limited NRC guidance on licensee reportability requirements under 10 CFR 50.69. Additionally, guidance developed by the industry has not been endorsed by the NRC and is potentially contrary to regulatory requirements. The working group recommends developing inspector guidance on 10 CFR 50.69 reportability.
The working group recognizes that the appropriate location for this guidance would be NUREG-1022, Event Report Guidelines 10 CFR 50.72 and 50.73. However, pending a revision to the NUREG to add a section on 10 CFR 50.69, the working group recommends adding guidance to address this issue in IP 37060.
Alternatively, NRC review and endorsement of industry reportability guidance related to risk informed initiatives, including 50.69, as acceptable would also serve to resolve this recommendation.
Level of Effort: High Benefit: High Acton the recommendations:
The working group will implement the decisions of management on these recommendations.
Regardless of the acceptance of the recommendations above, IP 37060 can be performed as is.
3.
Conclusion:
The working group assesses that the cumulative impact of the recommendations will result in a high level of benefit for inspectors implementing IP 37060 as well as resident inspectors at nuclear power plant sites applying 10 CFR 50.69 programs. Overall level of inspection effort to perform IP 37060 is expected to remain steady or decrease through implementation of these recommendations. Improved inspector guidance and training will reduce inspection preparation requirements. Therefore, the working group recommends acceptance of all of the proposed recommendations in this summary.
10