May-June 2019 NPJ

34 NuclearPlantJournal.com Nuclear Plant Journal, May-June 2019 On the other hand, I am concerned that a near-term rulemaking to establish this new regulatory framework could shift focus away from the current efforts to improve key guidance documents, at a time when significant progress is being made. I do not want to lose themomentum we have right now. And if updated guidance is able to effectively resolve the major regulatory challenges and provide a predictable framework for making digital upgrades, I have a hard time seeing the case for setting that guidance aside and starting from scratch with a new rule. Instead of deciding now whether to initiate a rulemaking sometime down the road, I think it would be better to first see whether updating the guidance proves to be an effective solution. Although I am open-minded about ultimately pursuing a transformative digital instrumentation and control rulemaking, I believe the staff should complete the ongoing efforts, allow the new guidance to be used for a period of time, and then determine the extent to which the new guidance has resolved the challenges in this area. At that point, we can decide whether a rulemaking is still needed. There are a lot of ideas for making changes to the engineering inspection program – some good and some not so good. Engineering inspections are an essential part of the suite of baseline inspections conducted at every operating nuclear power plant across the country. They “play an important role in verifying that safety systems are capable of performing their intended safety functions under accident conditions.” NRC began conducting engineering inspections in response to a significant safety event at Davis-Besse in 1985, and these inspections have evolved over the years to confront emerging issues and new findings. As the NRC staff’s Engineering Inspection Working Group concluded, “the current suite of engineering inspections is effective in identifying safety issues.” In fact, since the year 2000, these inspections have resulted in over 2,000 inspection findings. Most of the findings were green, but several were white or even yellow. The Working Group explained that one of the reasons the engineering inspection program “added value to reactor safety was its ability to identify latent conditions that would not manifest themselves through routine plant surveillance activities.” This helped NRC inspectors identify defective components before they failed. So although many of the performance deficiencies identified over the years were of lower risk significance, some of these deficiencies would have become more risk significant if NRC hadn’t caught them early, before component failure. The Commission is currently considering options for modifying the engineering inspections. The staff recommends replacing the current Design BasesAssuranceInspectionandsomeother regional team engineering inspections with a Comprehensive Engineering Team Inspection complemented by Focused Engineering Inspections. The Comprehensive Engineering Team Inspection would verify the ability of plant components to perform their licensing basis functions following plant modifications. The staff recommends performing them on a four-year cycle. In the years they are not performed at a plant, a Focused Engineering Inspection would be performed instead. These inspections would more narrowly focus on a particular engineering area, which would change each year. So there are two basic changes being contemplated here. First, a shift in the content and focus of each year’s engineering inspection; and second, a reduction in the frequency of the comprehensive engineering inspection. I believe the first change would improve both safety and efficiency. The second change would do neither; NRC would just be doing less. There is a solid safety basis for moving from the current inspection to the newly designedinspections,whichweredeveloped based on feedback from inspectors in the field. The safety advantage of the Focused Engineering Inspection is that it will focus on different and often uninspected, safety- significant areas each year. This provides the NRC staff with the flexibility to shift the engineering inspection focus to areas of emerging need as the nuclear power plant fleet ages. On the other hand, reducing the frequency of the comprehensive engineering inspection from once every three years to once every four years would reduce inspections solely to reduce costs. The baseline inspection program is at the heart of what NRC does to ensure that nuclear power plants operate safely. There is no persuasive rationale rooted in safety for reducing the frequency of comprehensive engineering inspections. NRC should not inspect less in order to save money. Some stakeholders argue that NRC should accept licensee self-assessments in lieu of independent NRC engineering inspections. They suggest that NRC allow industry self-assessments to replace NRC inspections in other areas too, such as radiation protection, emergency preparedness, and security. NRC should not head in this direction. These are foundational, baseline inspections that, since the beginning of the Reactor Oversight Process, have been viewed by NRC as necessary for every nuclear power plant in the country, regardless of licensee performance. These baseline inspections are essential, and NRC inspectors need to be independently conducting them. We should not allow licensees to inspect themselves in lieu of NRC inspections. We need to ask ourselves: why does NRC conduct inspections in the first place? Because our independent inspectors find problems that licensees don’t. Because licensees perform better and more safely with us performing rigorous independent oversight. Because the public has entrusted NRC, a public agency that works for them, with the responsibility of establishing standards to protect their health and safety and enforcing those standards impartially. None of those purposes are met when licensees are allowed to inspect themselves. This concept is fundamentally inconsistent with our mission as an independent safety regulator. There is nothing wrong with licensees performing self-assessments for their own purposes. In fact, licensees routinely conduct self-assessments in advance of significant NRC inspections to gauge their readiness. But when NRC inspectors then conduct those inspections, our inspectors still identify issues that the self-assessments did not. The thousands of engineering inspection findings over the years conclusively demonstrate that. Several other transformation concepts being discussed involve different aspects of the Reactor Oversight Process. As a general matter, I would be wary of making any radical changes to the Reactor Oversight Process because it has generally been an effective safety framework. The program is not Transformation &... ( Continued from page 33)