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POLICY ISSUE SECY-05-0118 July 1 , 2005
PURPOSE: The purpose of this paper is to provide the Commission the staff's assessment of the results of the pilot program to improve the effectiveness of Nuclear Regulatory Commission (NRC) inspections in the design and engineering area. The paper also contains a summary of the planned changes to NRC programs based on the assessment results. SUMMARY: In SECY-04-0071, “Proposed Program to Improve the Effectiveness of the Nuclear Regulatory Commission Inspections of Design Issues,” the staff described its plans to implement a three-part program to improve the NRC’s ability to identify significant design issues at commercial nuclear power facilities. Phase 1 of the program involved data analysis of recent design and engineering issues. The results of Phase 1 were given in SECY-04-0071. Phase 2 of the program involved the development of a new inspection approach and the conduct of four pilot inspections. These four pilot inspections have now been completed. Phase 3 of the program involved analysis of the pilot inspection results and the development of program changes. A summary of the Phase 3 analysis and the planned program changes, including enhancement to the baseline engineering inspection and inspection of power uprates, are included in this paper. The recommended program changes will result in additional contractor expenditures which have been reflected in the FY 2006 and FY 2007 budgets. BACKGROUND: As previously stated in SECY-04-0071, licensees must demonstrate to the NRC that plant systems and components are designed with sufficient margins and redundancy to ensure they can perform their intended safety-related functions. After granting an operating license, the NRC relies on the licensee to maintain the facility’s design in accordance with its licensing requirements. In addition, recent risk-informed initiatives intended to reduce unnecessary regulatory burden are based in part on the assumption that the changes requested do not result in an unacceptable risk to public health and safety despite reductions in margin or redundancy. To support this assumption, the NRC staff and its licensees rely on calculations and analyses that predict the performance of the facility under various accident sequences. Therefore, the accuracy of these design basis calculations and analyses has become increasingly important as the industry and NRC implement new risk-informed regulatory initiatives. It is also important that NRC inspection resources be directed towards aspects of the plant design and operation that represent the most risk and that those resources be implemented as effectively as possible. DISCUSSION: Summary of Phase 1 Data Analysis and Phase 2 Pilot Program Development In the Phase 1 analysis documented in SECY-04-0071, the NRC staff summarized its review of 3 years of data from the Reactor Oversight Process (ROP) to see whether NRC inspections and licensee self-assessment efforts had been effective in identifying latent engineering and design issues. The results of the review highlighted the need for aggressive licensee self-assessments in the design area and effective corrective action programs that can evaluate and resolve the identified issues in a timely manner. The results also showed that in some instances, the NRC had indications of programmatic design and engineering weaknesses, but did not engage the licensee’s further, since the programmatic weaknesses had not yet resulted in issues classified as risk-significant through the ROP’s Significance Determination Process (SDP). Using the insights gained from its Phase 1 review, and based on its review of existing and past NRC inspection practices in the design and engineering area, the staff developed a prototype inspection module to focus on aspects of the facility’s design that represented a relatively high degree of risk and for which there appeared to be relatively low margin. This inspection module, “Temporary Instruction 2515/158 Functional Review of Low Margin/Risk Significant Components and Human Actions,” was implemented at one site in each of the four NRC regions: Vermont Yankee, V.C. Summer, Kewaunee, and Diablo Canyon. Phase 3 Assessment of Pilot Program Results The staff’s assessment of the pilot inspection results has been an iterative process, with changes being made to the pilot inspection approach based on lessons learned from each of the pilot inspections. In addition, following the completion of the last of the four inspections, the NRC staff and contractors most directly involved with the pilot inspections conducted a detailed review of the program results and developed recommendations for enhancing the current NRC baseline inspections in the engineering area. The staff’s assessment included the inspection approach and content, the inspection frequency, staffing, and training considerations. A separate group conducted an assessment of the Vermont Yankee pilot inspection results and developed preliminary recommendations for enhancing the NRC inspection process for licensee requests for power uprates. A member of the NRC’s staff also participated in a panel discussion with pilot inspection recipients at a recent American Nuclear Society conference and received feedback regarding the inspection approach from the industry’s perspective. The pilot program was also discussed with external stakeholders at the 2005 Regulatory Information Conference during the regional breakout sessions, and during a monthly public NRC/industry working group meeting to discuss issues associated with the ROP. CONCLUSIONS: Effectiveness of Pilot Inspection Approach The staff concluded that the pilot inspection approach resulted in improvements that should be incorporated into the baseline inspection program. The effectiveness of the pilot inspections was largely attributed to:
The staff plans to incorporate these attributes into a revised baseline inspection procedure to be implemented beginning January 1, 2006. The revised inspection procedure will be conducted over a seven week cycle, including three weeks of onsite inspection. This is similar to the approach used during the pilot inspections. The recommended team composition will consist of an NRC team leader, two design contractors (typically one mechanical and one electrical/IC), one regional operations inspector, one regional engineering inspector, and one inspector trainee. This is a reduction of one contractor and one NRC inspector from the approach used during the pilot inspections. The Office of Nuclear Reactor Regulation (NRR) will conduct a short general training session for team leaders and/or regional inspectors covering the revised inspection approach. Consistent with the current baseline approach, this inspection will be performed biennially (once in every two-year ROP cycle). Since future inspections will include samples of relatively greater margin and lower risk than those in the first round, consideration will be given to reduced-scope inspections and/or licensee self-assessments, based on performance during the first round and other existing objective criteria. The staff plans to develop specific guidance in this area following the completion of the first year of the program and prior to completion of the first two-year cycle. Included will be specific criteria for determining the appropriate scope and/or staffing of future inspections, including guidance for allowing credit for licensee self assessments. Assessment of Pilot Inspection Results The results of the pilot inspections appear to indicate that latent design and engineering issues, mostly of very low safety significance,1 persist at operating reactors. The pilot inspections resulted in 29 inspection findings. Of interest was the number of inspection findings that involved inadequate operating procedures and the operations-design interfaces. The pilot inspections focused on these areas which had not recently received significant inspection attention. The staff plans to continue this focus during future inspections. Also noteworthy was the large number of findings that involved inadequate corrective actions. This is consistent with other recently performed NRC evaluations in this area. The focus on corrective action programs and their effective implementation remains an important element of the ROP. A more detailed analysis of the inspection findings and a comparison against baseline inspection program data are given in Attachments 1 and 2. In aggregate, the pilot program results support the need for continued inspection focus in the engineering and design area. However, the results do not indicate the existence of widespread risk-significant issues. As such, the staff plans to enhance, rather than revamp, its approach to inspection and oversight in the design and engineering area. The staff concludes that many aspects of the approach used during the pilot inspections should be incorporated into the current baseline inspection program. Regional Staffing Considerations In order to effectively implement future inspections, the staff believes that each region should form a core group of inspectors and team leaders for the inspections. This will help in scheduling both staff and contractors and will allow more consistency from inspection to inspection. Also, a branch chief should be designated in each region as the inspection procedure lead. The regional branch chiefs and the NRR lead will form a focus group that will meet periodically to assess the effectiveness of this part of the inspection program. Parallel ROP Changes The staff also looked at what parallel changes might be needed to other aspects of the ROP to address engineering and design inspection issues. The staff identified that enhanced guidance is needed in Inspection Manual Chapter (IMC) 0612 to define what types of engineering and design issues should be considered “minor” or greater than minor. This guidance is important, since issues identified as being minor are typically not documented in NRC inspection reports and are not included in NRC cross cutting issue assessments. The staff is planning to address this concern by revising IMC 0612 prior to the end of calender year (CY) 2005. The staff believes that no other changes to the ROP are necessary at this time. The staff will revisit the question of other parallel ROP changes after revising the IMC 0612 guidance and conducting the revised engineering and design inspections for one year. Assessment of Power Uprate Inspection Approach In response to the Commission’s Staff Requirements Memorandum M041209, dated December 23, 2004, the staff performed a preliminary assessment of the results of the Vermont Yankee inspection, with the goal of determining whether the NRC needs to enhance the current inspection process for power uprate license amendment requests. Traditionally, the NRR technical staff has reviewed license amendment requests in detail for a power uprate, but the inspection part of that review has been limited. The pilot engineering inspection at Vermont Yankee was an attempt to perform an in-depth inspection of aspects of the facility’s design that would be impacted by the requested power uprate. The staff has reviewed the results of the Vermont Yankee inspection and has concluded that the current power uprate inspection procedure should be enhanced. In addition, a process should be developed to better integrate the inspection and NRR technical review process for power uprates and other important license amendment requests. These conclusions are based primarily on the identification of several issues during the Vermont Yankee inspection. These issues involved the acceptability of the licensee’s power uprate submittals with respect to the Station Blackout Rule, motor-operated valve testing, certain operator response times, and certain assumptions in accident analyses. The staff believes it unlikely that these inspection-identified issues would have been identified by subsequent NRR technical reviews, because the NRR technical reviews rely primarily on licensee-submitted documentation. The staff therefore believes a detailed inspection is a good complement to the NRR technical review in this area. To address the above concerns, the staff plans to perform a more detailed assessment of what specific changes should be made to the inspection part of the power uprate process. The staff will also develop a process for better integrating inspections and NRR technical reviews for important license amendment requests. This assessment, as it relates to power uprates, should be completed before the end of CY 2005. COMMITMENTS: Listed below are the significant actions or activities planned by the staff to improve the effectiveness of NRC inspections in the design/engineering area:
RESOURCES: NRC staff hours to revise the baseline inspection procedures, conduct training, and perform program management are currently budgeted. This work is estimated to be approximately 0.25 FTE. The planned changes for the first round of inspections should result in a savings of about 1 FTE per year that will be used to help complete other baseline or supplemental inspections. However, there will be an increase in the use of contractor funds for the first round of inspections. It is estimated that contract support needs will total about $70K per inspection. Assuming 33 inspections per year, approximately $2.3 million dollars per year of contract support will be needed. This is in contrast to the approximate $500K allocated to engineering inspections in fiscal year (FY) 2005. Sufficient funds to cover this planned increase in contract support have already been included in the FY 2006 and 2007 budgets. It is anticipated that after the first round of inspections, the scope of some inspections may be reduced and that consideration may be given to crediting licensee self-assessments in lieu of some NRC inspections in this area. This may result in a reduction in total inspection effort in the subsequent rounds of inspections. COORDINATION: The Office of the General Counsel has reviewed this Commission paper and has no legal objections to its content. The Office of the Chief Financial Officer has reviewed this Commission paper for resource implications.
CONTACT: Jeffrey Jacobson, NRR/DIPM 301-415-2977 |
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