COM-106, Tia(Tar) NRC Staff Slide Presentation for Category 2 Public Webinar with NEI and Industry on July 27, 2020

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COM-106 Tia(Tar) NRC Staff Slide Presentation for Category 2 Public Webinar with NEI and Industry on July 27, 2020
ML20205L300
Person / Time
Issue date: 07/23/2020
From: Booma Venkataraman
Division of Operating Reactor Licensing
To:
Venkataraman B
References
Download: ML20205L300 (15)


Text

COM-106 Program Revitalization Technical Assistance Request TAR Office of Nuclear Reactor Regulation (NRR)

Category 2 Public Webinar with NEI and Industry To discuss comments on TIA Ca Draft updated office instruction COM-106 Task Interface Agreement July 27, 2020

AGENDA Opening Remarks. Division Management, NRR, Division of Operating Reactor Licensing (DORL)

Staff Overview Presentation.. NRR Booma Venkataraman Alex Schwab Discussions.. NRR with NEI and Industry Opportunity for Public Comments Closing/ Summary 2

TECHNICAL ASSISTANCE REQUEST (NRR COM-106) -HIGHLIGHTS TIA (TAR)

TIA RESTRUCTURED!

As a fact-gathering exercise to inform decisionmaking in other processes (e.g., enforcement, backfitting), it offers:

modernization (e.g., holistic solutions) a graded, risk-informed approach enhanced effectiveness and timeliness 3

COM-106 REVITALIZATION STAKEHOLDER TOUCH POINTS NRC working group kicked off on Jan 31, 2019

  • Public engagements with industry were held on March 19, May 29, and Nov 7, 2019.
  • The Nov 7, 2019 meeting featured table-top style discussions on the proposed process.
  • An interim draft version of the COM-106 guidance was made publicly available on Dec 5, 20191 for general awareness.
  • Feedback sought/ Training for staff May- Dec, 2019 and in June 2020- NRR and Regions.
  • NEI provided general comments on Feb 11, 20202, on the interim draft for NRCs consideration and discussion at a future public engagement.
  • An updated draft version of the COM-106, was made publicly available on July 9, 20203, in a public teleconference.
  • This webinar is for discussing industry and public comments on the draft COM-106 issued on July 9, 2020.

1 ADAMS Accession No. ML19338E029.

2 ADAMS Accession No. ML20043F478.

4 3 ADAMS Accession No. ML20178A474.

New Graded Approach 3-Phase Graded Approach and Construction TAR to Efficient and Effective Issue Scoping, Process RoutingIntegration and Resolution

  • Boosted collaboration with requestor
  • Enhanced 3 licensee Safety engagement at Significance every step 2 1 IN-DEPTH REVIEW SCREENING AND Unresolved INTAKE EVALUATION question(s) TAR In-depth from routine ~ 30 day goal Review

~ 8 hr. goal processes Response Intake forms TAR Screening and TAR referral, Evaluation Results response or Construction TAR Process Memorandum recommendations

~ 30 day goal Construction TAR response will be recorded on the Intake form Actions/

Decisions in

  • Early alignment: Integrated Team Routine
  • Disputed facts: OGC on board early Processes
  • Rigor in scoping/ framing questions 5

Integrated VLSSIR-TAR-BACKFIT NEXUS Decisionmaking principles Backfit Process MD 8.4, NUREG-1409,*

NRR/NMSS Office Instructions*

6

  • Issue Mapping: Licensing Basis Standing and Safety Significance High Safety Significance Not or not clearly within the licensing Clearly within the licensing basis basis but may have safety and may have safety significance significance Determine regulatory actions using:

Determine regulatory actions using:

  • Reactor Oversight Process
  • Technical Assistance Request
  • Enforcement
  • 50.54(f) letter
  • Order
  • Backfitting Not Within
  • Generic issue process Within Licensing Licensing Basis Basis Not clearly within the licensing basis but Clearly within the licensing basis clearly very low safety significance but clearly very low safety significance Do not expend significant resources: Address with appropriate tools:
  • Inspect corrective actions to restore
  • Document decision compliance
  • Make public record
  • Evaluate proposed change to licensing basis
  • Consider rulemaking Low Safety 7 Significance

VLSSIR* CRITERIA: GUIDANCE IN IMC 0612, APPENDIX B (ISSUE SCREENING)

If the current licensing basis question cannot be determined without a significant level of effort, then the issue may be closed as part of the VLSSIR process. This process can be used if all of the following are met:

The licensee has demonstrated, by providing a supporting basis, why the issue of concern is not in its current licensing basis; and The inspector (using the resource estimate in the applicable inspection procedure as a guideline and which may involve NRC Headquarters support) has not been able to conclude the issue of concern is part of the plants licensing basis; The issue (if it were assumed to be an inspection finding) has been confirmed as very low safety significance (would not have proceeded to a detailed risk evaluation, a Phase 2 evaluation when relevant, or Appendix M, if processed through IMC 0609, Significance Determination Process as a performance deficiency); and Branch Chief concurrence that spending more time in researching the current license basis is not likely to benefit public health and safety relative to other inspection activities.

If all of the above are met, document as:

IAW IMC 0611-12, Minor Performance Deficiencies, Minor Violations, Observations, Assessments, and Very Low Safety Significance Issues 8 *VLSSIR is a recommendation of LSSIR: Low Safety Significance Issue Resolution Effort (WG recommendations memorandum, ADAMS Accession No. ML19260G224).

Journey of an Inspection Issue with a Licensing Basis (LB) Standing Question 9

TAR: SAFETY SIGNIFICANCE DETERMINATION Integrated TOOL (IN SCREENING & EVALUATION) Decisionmaking 10

COM-106 JOURNEY NEXT STEPS (ESTIMATED TIMELINE)

Public industry engagement: July 2020 Completion of COM-106 update: Aug 2020 11

DRAFT COM-106 DISCUSSION WITH NEI/INDUSTRY 12

PUBLIC COMMENTS 13

CLOSING REMARKS/

SUMMARY

14

Stay safe, and healthy!

Thank You 15