NRC Staff Recommends Scaling Back Reactor Inspections

In a bid to enhance the reactor oversight process (ROP), staff at the Nuclear Regulatory Commission (NRC) has recommended the commission change qualitative descriptions for some color labels that signify risk, scale back on the time and scope of some annual inspections at the nation's nuclear power fleet, as well as increase intervals between inspections.

The recommendations stem from a January 2018 memorandum from the NRC's executive director of operations that tasked staff with identifying "potential transformational changes" to the NRC's "regulatory framework, culture, and infrastructure to further enhance effectiveness, efficiency, and agility in regulating novel technologies." To carry out the task, a "Transformation Team," solicited feedback from internal and external stakeholders. Its recommendations were narrowed into specific action items that staff published in a June 28 "notation vote," a document that the NRC made public this week.

Only a handful of those recommendations, however, came from the Nuclear Energy Institute (NEI), a trade group whose members include nuclear plant operators, reactor designers, fuel suppliers, and service companies.

The trade group suggested 27 recommendations, though it stressed in a September 2018 letter to the NRC, that the ROP, established 20 years ago, remains sound, and it has helped in "incentivizing good performance." The NEI also noted that while the ROP has evolved in response to operating experience, the U.S. power reactor fleet has matured, accumulating more than 4,000 reactor-years of operating experience. In that time, the sector has also improved safety margins through shared learning and best practices, improved risk assessments, and made more decisions that are informed by risk.

During the ROP process, NRC inspectors generally implement inspection procedures, and nuclear plant operators report performance indicator (PI) results to the NRC. The NRC also tracks the ROP through an "action matrix"-essentially a graded approach that the agency uses to respond to performance issues.

Currently, Green inspection findings suggest a "very low safety or security significance" and that the NRC's cornerstone objectives are fully met. The significance of White findings are "low-to-moderate"; Yellow are "substantial"; and Red are "high." White, Yellow, and Red findings require that the NRC conduct supplemental inspections.

The NEI also urged the NRC to reduce "unproductive impacts" to White findings; to resolve challenges to the licensing basis; to open up communication about inspection issues, and significantly, to reduce baseline inspection hours and simplify the mitigating systems PI.

As part of "high priority" recommendations, it urged the NRC to get rid of the press releases for White findings, reduce the burden of radiation protection and emergency preparedness inspections, eliminate materials inspections of independent spent fuel storage installations, and establish a process to resolve the "very low risk" questions about the licensing basis.

But in recommendations to the commission this June that NRC staff crafted after weighing stakeholder feedback, it chose a narrower focus in areas concerning assessment, inspection, and emergency preparedness.

Perhaps most notable are changes to the qualitative descriptions of a White inspection finding from "low-to-moderate" to "low" safety significance and to change the description of a Yellow inspection finding from "substantial" to "moderate" safety significance. However, it did not change the Green and Red labels.

NEI noted that the changes would clarify "the communication aspect of the color and eliminates color definition overlap that is confusing and sends a message that there is only a broad understanding of the significance rather than a true understanding of a more precise characterization of significance."

Also important are proposed staff changes to sample sizes and resource estimates for several baseline inspection procedures. Specifically, it proposed to eliminate IP 71124.02, "Occupational ALARA [As Low as Reasonably Achievable] Planning and Controls," from the radiation protection inspection program. Staff also recommended extending the intervals between problem identification and resolution (Pl&R) inspections from every two years to every three years.

"The staff believes these revisions will better risk-inform and improve efficiency and effectiveness of the program while still providing assurance that the cornerstone objectives are being met. Effectiveness will be improved by fewer resources being expended on lower risk areas, such as ALARA, so that inspectors can spend more time on issues of greater safety significance. Better risk-informing the inspections and eliminating redundancies will also improve effectiveness because inspectors again will be focused on issues of greater safety significance," it said.

The changes respond to industry concerns that the amount of baseline direct inspection hours has increased by approximately 30% since 1999, when the program was established. Industry urged the NRC to slash overall baseline inspection program hours by 20%-and at least 25% for higher performing plants, which NEI said could be defined as "having no greater than Green inputs to the action matrix in the past 12 months."

NRC staff, however, pegged its assessment on resource hour "estimates" instead of actual inspection hours because "the estimates were based on documented inspection requirements." Since the program's inception, yearly resource estimates to complete the baseline inspection program increased more than 10%-but that was mainly due to a number of orders the NRC issued after the 9/11 terrorist attacks that required licensees to strengthen security programs.

In its July 8-issued 2018 Annual Report to Congress, the NRC said it conducted 192 security inspections at commercial nuclear power plants and Category I fuel cycle facilities in 2018. "Those included 21 force-on-force inspections, involving simulated attacks on the facilities to test the effectiveness of a licensee's physical protection program," it told POWER in a statement.

The table above summarizes the historical and current annual nominal resource estimates for a two-unit pressurized-water reactor facility and the staff's proposed resource estimates in hours to complete the baseline inspection program for all inspectable areas. It shows that "for the current baseline inspection program, there were substantial increases in security and other procedure resource requirements, while reactor safety baseline inspection resource requirements decreased from year one of the ROP," NRC staff said.

As significantly, staff opted not to address the NEI's recommendation that the NRC promptly close White findings as soon as inspector follow-up is completed-mainly to ensure that inspection attention is only maintained if a risk is ongoing. Staff warned that the PI could return to Green without the licensee taking corrective action.

Instead, it proposed to remove greater-than-Green (GTG) inspection findings as ROP action matrix inputs, so long as operators had successfully completed the necessary supplementary inspection. "Currently, these findings remain as Action Matrix inputs for at least four full calendar quarters," staff noted.

It also proposed to revise the treatment of GTG performance indicators so that they remain action matrix inputs until a supplemental inspection is completed. "Currently, if a Pl returns to Green, it is no longer an Action Matrix input, so it does not aggregate with other GTG inputs, even though the licensee remains in the higher Action Matrix column until the supplemental inspection is completed."

That option would incentivize licensees to correct GTG findings and Pis and declare readiness for supplemental inspections as soon as practicable, it said. "The proposed change eliminating the minimum four-quarter requirement change for findings could be construed as a relaxation of regulatory oversight by reducing the time for aggregation of Action Matrix inputs," it noted. However, "net impact would be neutral when considering the proposed change to the treatment of GTG PIs," it said.

Finally, it recommended a revision to the emergency preparedness (EP) significance determination process (SDP) so that only those planning standard functions that have an impact on public health and safety would have performance deficiencies assessed to have GTG safety significance.

The NEI urged the NRC to implement these changes, noting that EP SDP can generate GTG outcomes for performance deficiencies that appear to be less risk-significant than those that result in GTG outcomes in other SDPs. Staff agreed for the most part, saying the changes could improve "the efficiency and effectiveness of the EP SDP, with inspectors spending less time determining significance of inspection findings that do not have a direct impact on public health and safety." However, it noted important disadvantages, one of which is that they could result in a "misperception that non-[risk-significant planning standard] functions are not important elements of the emergency plan."

The recommendations will need approval by the NRC's commissioners. Three of the four confirmed commissioners are President Trump appointees-Chair Kristine Svinicki, Annie Caputo, David A. Wright. Only one is an Obama appointee-Jeff Baran. One seat in the five-member commission remains vacant.

However, as the Associated Press reported on July 17, and as notes in the document show, the recommendations were reached after considerable disagreement. The Associated Press quoted Baran as saying, "NRC shouldn't perform fewer inspections or weaken its safety oversight to save money." Baran urged the NRC to give the public an opportunity to discuss before it decides on whether to approve the changes.

-Sonal Patel is a senior associate editor at POWER (@sonalcpatel, @POWERmagazine)

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