ML23156A231

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5/18/2023 Summary of the Reactor Oversight Process Bi-Monthly Public Meeting
ML23156A231
Person / Time
Issue date: 06/05/2023
From: David Aird
NRC/NRR/DRO/IRAB
To: Philip Mckenna
NRC/NRR/DRO/IRAB
References
Download: ML23156A231 (8)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 5, 2023 MEMORANDUM TO: Philip J. McKenna, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: David M. Aird, Reactor Operations Engineer /RA/

Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF THE REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING HELD ON MAY 18, 2023 On May 18, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with the Nuclear Energy Institutes (NEIs) Reactor Oversight Process (ROP) Task Force executives, other senior industry executives, and various external stakeholders to discuss the staffs progress on initiatives related to the ROP. The topics discussed during this hybrid meeting are described below.

ROP Enhancement and Self-Assessment Activities for Calendar Year 2023 The NRC staff provided an update on the status of the ROP Enhancement Commission SECY papers schedule (ADAMS Accession No. ML22025A132). At the April 2023 ROP public meeting the NRC staff provided an overview of the status of implementing Commission direction in SRM-SECY220086, Recommendations for Revising the Reactor Oversight Process Assessment Program, dated March 10, 2023. The staff described planned changes to Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. As part of this revision the staff briefed that the definition for a held open finding was being changed to a finding that remains open when a licensee does not satisfy all objectives of the supplemental inspection, and the date of closure for a held open finding would be the date of issuance of the satisfactory supplemental inspection and assessment follow-up letter. The IMC 0305 revision was issued on May 4, 2023, and the NRC decided to keep the closure date the same for satisfactory completion of supplemental inspections and if a subsequent supplement inspection is necessary. The closure date will be the date of the supplemental inspection (or subsequent supplemental inspection) exit meeting. The term held open finding was removed from IMC 0305.

CONTACT: David M. Aird, NRR/DRO 3012870725

P. McKenna The proposed performance indicator (PI) change to retire the Indicator for Licensee Alert and Notification System Availability and to Develop a Performance Indicator for Emergency Response Facility and Equipment Readiness, SECY230010, (ML22252A129) was issued on January 30. 2023 and the Commission has not completed voting on this SECY. The White/Yellow findings description revision in IMC 0609 is ready to be issued but will wait until a corresponding change to the Enforcement Policy is sent to the Commission by a SECY paper.

This SECY paper is expected to be issued in June 2023.

The NRC staff discussed the plans for the ROP Self-Assessment Activities for 2023 which include completion of the Safety Culture Effectiveness Review that began in 2022, the Region II ROP Implementation Audit, and a program area evaluation that will consist of a review of the security significance determination process (SDP).

Insights from Age-Related Degradation (ARD) Public Workshop The NRC staff described a summary of the webinar public workshop conducted on April 18, 2023, regarding the new inspection, Age-Related Degradation. The summary of that meeting can be found on the NRCs public website and at ML23137A051.

The NRC staff shared that training of the NRC inspection staff was starting for the ARD inspections and that the first ARD inspection will be completed after July 2023. The slides for the NRC inspection training can be found on NRCs public website and at ML23138A285. Staff also indicated that NRC cross-regional panels will be held following the inspection completion prior to the inspection report issuance. Staff also addressed questions from the nuclear industry regarding implementation of the inspection procedure.

The NRC staff discussed that it is open to holding future public meetings after inspector training to share any insights from the training with external stakeholders.

Age-Related Degradation Summary of April 18 Public Workshop - ML23137A051 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23137A051 Age-Related Degradation Inspector Training Slides - ML23138A285 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23138A285 Plan for revising Inspection Procedure 71152, Problem Identification and Resolution The NRC staff presented a status of upcoming changes to the Problem Identification and resolution (PI&R) procedure, IP 71152. The staff discussed SRM-SECY220087, which provided Commission direction to NRC staff to; (1) maintain the PI&R team inspection at a biennial frequency and (2) maintain the current inspection hours for the procedure. As a result of the recommendations from the PI&R comprehensive review (ML20247J590), NRC staff will update the procedure format and include additional assessment guidance for the performance and documentation of biennial team inspections. In addition, the staff will close all outstanding ROP feedback forms and lessons learned actions related to IP 71152.

Presentation - PI&R Procedure Brief for May 2023 ROP Public Meeting - ML23136A589 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23136A589 P. McKenna Proposed Industry Frequently Asked Questions (FAQs)

Representatives from NEI and industry introduced FAQ 2302 where guidance for interpretation of BWR Flowchart questions 2 and 5 for a Peach Bottom reactor scram on May 16, 2022. The initiating event for the scram was deenergization of both buses of the reactor protection system (RPS). This resulted in a reactor scram and Group 1 isolation, closing all main steam isolation valves (MSIVs). All control rods inserted as expected during the scram. Four safety relief valves (SRVs) of the 11 SRVs opened to mitigate the reactor pressure rise, as expected. Following the initial transient, operators established pressure control in accordance with T101, RPV Control, which is entered as part of normal scram response. Additionally, the response was aligned with procedure OPPB101111-1001, Strategies for Successful Transient Mitigation. Reactor Core Isolation Cooling (RCIC) was the primary method of level control with initial supplementation from High Pressure Coolant Injection (HPCI). Operators utilized SRVs manually in addition to HPCI in pressure control mode to maintain reactor pressure, as outlined in station procedures.

No SRVs cycled automatically subsequent to the initial transient, and no SRVs failed open.

Representatives from NEI and industry also introduced a whitepaper - Modification of the Description of Unplanned Scrams with Complications [USwC] Performance Indicator to Reflect AP1000 Design. This whitepaper describes changes to NEI 99-02 needed to add AP1000-specific features and terminology to the USwC performance indicator guidance. These changes provide clarity for use with the AP1000 plant terminology, design, and procedures.

FAQ 2302 Peach Bottom Performance Indicator Interpretation Request - ML23136A605 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23136A605 Whitepaper - Modification of the Description of Unplanned Scrams with Complications Performance Indicator to Reflect AP1000 Design - ML23136A607 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23136A607 Update on NEI 99-02 Revision 8 Staff from NEI provided an update on the upcoming revision 8 of NEI 99-02, Regulatory Assessment Performance Indicator Guideline, incorporating approved FAQs since revision 7.

Draft FAQ response on the applicability of Part 26 requirements to contractor travel time The NRC staff presented an overview of a draft response to an inquiry from the public concerning the accounting of work hours for contractors traveling from one nuclear power plant site to another. The presentation highlighted the considerations that the staff identified as important to responding to the inquiry and showed how the draft response was developed by drawing together existing guidance from Regulatory Guide 5.73, Fatigue Management for Nuclear Power Plant Personnel (ML083450028), NEI 06-11, Revision 1, Managing Personnel Fatigue at Nuclear Power Reactor Sites, (ML083110161), and responses to questions previously addressed by NRC in its responses to FAQs about managing fatigue. The purpose of the presentation was to solicit stakeholder comment on the draft response, noting comments were requested to be submitted via email to David.desaulniers@nrc.gov by June 19, 2023.

Following the staff presentation several meeting participants offered preliminary comments. One nuclear utility representative noted that tracking contractor travel time would be an additional burden on licensees as it was not a current practice for this licensee and time would be needed to be able to implement the guidance. Another licensee representative commented that travel time was not viewed as work for the licensee and that the question asked of the NRC concerned P. McKenna the contractors, rather than the licensees, responsibility for tracking the hours. A third representative questioned the applicability of the work hour control requirements given the applicability statement in 10 CFR 26.4.

Presentation - Draft FAQ Response on Applicability of Work Hour Controls to Contractor Travel Time - ML23131A397 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23131A397 Draft FAQ Response to public inquiry concerning applicability of 10 CFR Part 26, "Fitness for Duty Programs" requirements to contractor travel time - ML23121A212 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23121A212 Follow-up discussion on safety culture Staff from NEI discussed the highlights from the letter they submitted to the NRC on May 9, 2023 (ML23135A733) that reiterated their concerns with the implications of the staffs recommendations from the Safety Culture Effectiveness Review effort (ML22340A452). NEI had previously discussed their concerns during the April 5, 2023 ROP public meeting after NRC issued the Safety Culture Effectiveness Review working group report. The NRC staff highlighted that NRC management was currently evaluating the working groups recommendations and has committed to industry that the recommendations that NRC management decides for implementation would be brought back to a future ROP public meeting for discussion.

Letter - NEI Comments on NRC Safety Culture Program Effectiveness Review - ML23135A733 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23135A733 Presentation - NEI Safety Culture Presentation for ROP Public Meeting - ML23136A591 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23136A591 Closure of FAQ 2301 The NRCs proposed response to FAQ 2301 DC Cook Unit 1 Unplanned Scram Exemption Request (ML23090A226) was discussed at the April 5 ROP Public meeting.

The FAQ was finalized and approved after that meeting and is officially closed.

FAQ 2301 Rev. 1 DC Cook Unit 1 Unplanned Scram Exemption Request - ML23104A432 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23104A432 The Next ROP Meeting The next ROP bimonthly public meeting is tentatively scheduled for July 13, 2023.

Communicating with the NRC Staff At the start of all ROP public meetings, the project manager provides contact information for the public to use to provide their name as a participant in the meeting. This contact information is also provided for submitting questions and comments to the NRC technical staff. Please note that any questions and/or comments pertaining to the ROP can be sent to David.Aird@nrc.gov.

Questions and/or comments will be forward to the appropriate NRC staff. The Contact Us about P. McKenna ROP page on the ROP public website can also be used to submit questions and comments regarding the ROP (https://www.nrc.gov/reactors/operating/oversight/contactus.html).

Conclusion At the end of the meeting, NRC and industry management gave closing remarks. The industry representatives expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC management stressed the importance of the NRC being focused on providing reasonable assurance of public health and safety when considering changes to the ROP.

The following link contains the meeting agenda and other information:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23125A021 The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML23156A231 * = via email OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME DAird PMcKenna* DAird DATE 6/2/2023 6/4/2023 6/5/2023 LIST OF ATTENDEES REACTOR OVERSIGHT PROCESS BIMONTHLY PUBLIC MEETING May 18, 2023 - 9:00 AM to 12:00 PM Name Organization1 Name Organization Tim Riti NEI David Aird NRC Tony Brown NEI Alex Garmoe NRC Steve Catron NextEra Phil McKenna NRC Ken Mack NextEra Russell Felts NRC Brian McCabe NEI Ami Agrawal NRC Justin Wearn PSEG Marc Ferdas NRC Brett Titus NEI Don Johnson NRC Brad Dolan TVA Aron Lewin NRC Thomas Perry Dominion Antonios Zoulis NRC Stephenie Pyle Entergy Molly Keefe-Forsyth NRC Lee Marabella PSEG Billy Gleaves NRC Nicole Good STARS Alliance Rebecca Sigmon NRC Edwin Lyman UCS Hironori Peterson NRC Robin Ritzman Curtiss-Wright Dan Merzke NRC Larry Nicholson Certrec Paul Peduzzi NRC David Gudger Constellation Nuclear Stephanie Morrow NRC Phil Couture Entergy Zack Hollcraft NRC Francis Mascitelli Constellation Nuclear Hang Vu NRC Rob Burg EPM, Inc. Sarah Obadina NRC Tammy Morin PSEG Bridget Curran NRC James Pak Dominion Energy William Rautzen NRC Marty Murphy Xcel Energy Brian Hughes NRC Ryan Joyce Southern Nuclear Marcus Chisolm NRC Anthony Clore NEI David Garmon NRC Deann Raleigh Curtis-Wright Tom Hipschman NRC Justin Bouknight Dominion Ron Cureton NRC Melody Rodriguez NEI Tony Nakanishi NRC Travis Bennett Southern Nuclear Kate Lenning NRC Roy Linthicum Constellation Nuclear Julie Winslow NRC David Feitl NEI Chris Cauffman NRC Cecil Fletcher II Duke Energy Jared Justice NRC Richard Mogavero NEI Nicole Fields NRC Melisa Krick Talen Energy Andrew Mihalik NRC Jim Andersen Unknown Amar Patel NRC Matthew Marzano Unknown Jeff Bream NRC Shayne Curtis Xcel Energy Josh Havertape NRC Carrie Seipp Xcel Energy Paul Rades NRC Beth Lang Westinghouse John Hanna NRC 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Enclosure

Name Organization1 Name Organization Kate Atwater Westinghouse John Hughey NRC B. Cizin Unknown Sunil Weerakkody NRC Kelly Callais Unknown Avinash Jaigobind NRC Carlos Sisco Winston & Strawn Manuel Crespo NRC Rebeca Saiz Utanda Unknown Pat Finney NRC Wendy Brost Unknown John O'Donnell NRC Katie Brown Talen Energy Michele Kichline NRC James Orr Constellation Nuclear Ty Ospino NRC Alicia Davis Unknown Jason Eargle NRC Jim Slider NEI Paul Laflamme NRC Steven Dolley S&P Global Platts Rob Krsek NRC Ashley Rickey Constellation Nuclear Lundy Pressley NRC Wade Scott Constellation Nuclear Brian Kemker NRC Ryan Stiltner Constellation Nuclear Lauren Bryson NRC Drew Richards STP Tom Eck NRC Mark DeWire Unknown Virgel Furr NRC Stephen Yodersmith Unknown Noah Bolling NRC Isaac Mulhern Unknown Raju Patel NRC Robert Williams NRC Jonathan Fiske NRC Adam Lee NRC Musab Abuhamdan NRC Catherine Thompson NRC Zackery Helgert NRC William Schaup NRC 2