ML18178A587
| ML18178A587 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/2018 |
| From: | Joseph Holonich NRC/NRR/DLP/PLPB |
| To: | |
| Holonich J, NRR/DLP, 415-7297 | |
| References | |
| Download: ML18178A587 (21) | |
Text
© NEI 2018. All rights reserved.
OPERABILITY PROCESS ENHANCEMENT &
NEI 18-03 NRC PUBLIC MEETING JUNE 28, 2018
© 2018 NEI. All rights reserved.
© NEI 2018. All rights reserved.
PURPOSE
- Engage with NRC to enhance the predictability and efficiency of the Operability Determination process.
- Inform the NRC on the process contained in NEI 18-03, Operability Determination
- Identify areas within Inspection Manual Chapter (IMC) 0326 for revision 2
© NEI 2018. All rights reserved.
AGENDA
Background
Overview of the NEI 18-03 process Overview of crosswalk between IMC 0326 and NEI 18-03 Detailed discussion of six areas to gain predictability and efficiency
- Emphasizing that operability is the responsibility of the licensee
- Separating operability determinations from the Corrective Action Program (CAP)
- Defining common terms
- Establishing entry criteria
- Eliminating aspects not specifically tied to operability
- Ensuring operability is separate from ASME Code compliance Proposed engagement strategy and schedule 3
© NEI 2018. All rights reserved.
BACKGROUND
- At 2015 RUG III meeting, NRC questioned why industry relies on IMC 0326 for guidance (unique practice)
- Engagement with NRC during process development
- Control room burden of applying current OD process frequently not commensurate with safety significance
- Recent, high-visibility plant issues illustrated challenges to predictability and efficiency of OD process 4
© NEI 2018. All rights reserved.
NEI 18-03 OVERVIEW
- Clean sheet approach
- Use correct process tied to governing regulation and Technical Specifications (TS)
- If no process change, retained IMC 0326 concept/wording
- Guiding Principles
- Operability is a binary decision
- Operability is licensed operator responsibility
© NEI 2018. All rights reserved.
NEI 18-03 OVERVIEW
- Regulatory Basis
- Entry criteria
- Definitions
- Functionality
- ASME Code compliance 6
© NEI 2018. All rights reserved.
NEI 18-03 HIGHLIGHTS Foundation is TS definition of operability Items will continue to be reviewed and assessed
- Questions are addressed via correct process Emphasis of revised process is on entry
- Confirmed impact on operability Degraded or Nonconforming condition concepts eliminated Immediate and Prompt OD - no change to existing process Defined specified safety function Consistent with IMC 0326, do not attempt to specify detailed actions when performing operability
- Engineering judgment acceptable 7
© NEI 2018. All rights reserved.
COMPARISON TO IMC 0326
- Handouts provided in advance of meeting:
- Draft NEI 18-03
- Crosswalk/comparison between NEI 18-03 and IMC 0326 8
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SIX AREAS WHERE PREDICTABILITY AND EFFICIENCY CAN BE GAINED 9
Reference:
Letter from C. Earls to M. Gavrilas, Ensuring the Predictability and Efficiency of the Operability Determination Processes. May 22, 2018
© NEI 2018. All rights reserved.
PREDICTABILITY AND EFFICIENCY
- Operability is the responsibility of the licensee
- Consistent with concepts in IMC 0326
- Senior Reactor Operators are licensed by NRC and are responsible for compliance with the Technical Specifications 10
© NEI 2018. All rights reserved.
PREDICTABILITY AND EFFICIENCY
- Operability process is separate from CAP
- NEI 18-03 focus is on the definition of operability in the TS
- Operability decision is binary
- CAP focuses station resources on restoration of the deficient condition 11
© NEI 2018. All rights reserved.
PREDICTABILITY AND EFFICIENCY
- Eliminating aspects not specifically tied to operability
- Degraded and non-conforming condition classifications and functionality eliminated
- No regulatory basis
- Related to corrective action, not operability
- Distraction to the binary determination of operability
- Defining common terms
- Specified Safety Function defined
- Detailed derivation in Appendix B of NEI 18-03 12
© NEI 2018. All rights reserved.
SPECIFIED SAFETY FUNCTIONS 13 10 CFR 50.36(c)(2)(ii) requires an LCO be established on an SSC if it meets one of the criteria.
CRITERIA = LCO A TS LCO requires an SSC to be operable, equating LCO compliance with SSC operability.
LCO = OPERABILITY The TS definition of operability states that an operable SSC must be capable of performing its specified safety functions, equating operability with specified safety functions.
OPERABILITY = SSF Therefore, the regulations and the TS establish a link between the criteria in 10 CFR 50.36(c)(2)(ii) and the specified safety functions of an SSC.
CRITERIA = LCO = OPERABILITY = SPECIFIED SAFETY FUNCTIONS
© NEI 2018. All rights reserved.
PREDICTABILITY AND EFFICIENCY
- Establishing entry criteria 1.
The deficient condition must affect a TS SSC installed in an operating unit.
2.
The deficient condition must have a functional impact on the SSC. This includes the ability to perform required functions under postulated, off-normal design conditions.
3.
The functional impact of the deficient condition must be substantive (i.e., non-trivial).
- All three conditions must be met for immediate OD to be required
- SRO retains discretion to enter OD process at any time 14
© NEI 2018. All rights reserved.
PREDICTABILITY AND EFFICIENCY Ensuring operability is separate from ASME Code compliance
- References to Code compliance in IMC 0326 not generally included in NEI 18-03
- Determination of operability is separate from Code compliance
- Any technically acceptable method can be used to determine if a specified safety function can be met (alternate methods)
- Licensed operator decision -NRC approval not required if technically defensible method used to determine operability
- Restoration of Code compliance is governed by CAP and 10 CFR 50.55a 15
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PROPOSED ENGAGEMENT STRATEGY AND SCHEDULE 16
© NEI 2018. All rights reserved.
STRATEGY Apply lessons learned from successful and expedient engineering inspection streamlining effort
- NRC team composed of senior executive sponsor and headquarters and regional branch chiefs
- Industry team composed of regulatory and operations leaders empowered to make timely decisions
- Meeting locations include Rockville and regional offices to encourage inspector participation and awareness
- Meetings address distinct, specific technical issues
- Industry and NRC alternate who is in listening mode Scaled to align with impact of proposed change to operability 17
© NEI 2018. All rights reserved.
SCHEDULE (2018)
June Public meeting - Overview of NEI 18-03 July No meeting - NRC reads NEI 18-03 and aligns internally on understanding and concerns August Public meeting - NEI introduction of entry criteria September Public meeting - NRC feedback on entry criteria October Public meeting - NEI introduction of OD/CAP interface, definitions, and items eliminated from OD November No meeting December Public meeting - NRC feedback on OD/CAP interface, definitions, and items eliminated from OD 18
© NEI 2018. All rights reserved.
SCHEDULE (2019)
January Public meeting - NEI introduction of Code compliance changes February Public meeting - NRC feedback on Code compliance changes March No meeting - Ongoing work featured in panel discussion at Regulatory Information Conference April Public meeting - Finalize discussions, determine path forward (i.e. revision to NEI 18-03 and IMC 0326)
May No meeting - NEI incorporates feedback and transmits final NEI 18-03, NRC begins work on IMC 0326 revision June Final public meeting on OD 19
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SUMMARY
- Licensee continues to own operability
- Industry developed its own guidance to do so
- Limited changes to existing process
- No change to continuously assessing operability
- Adding predictable entry criteria
- Aligning to other plant processes to improve efficiency 20
© NEI 2018. All rights reserved.
QUESTIONS / DISCUSSION 21