ML081010229

Lesson Learned Inputs for the Reactor Oversight Program Safety Culture Evaluation for Use at 4/17/08 Public Meeting

ML081010229
Person / Time
Site:	Palo Verde
Issue date:	04/10/2008
From:	Office of Nuclear Reactor Regulation
To:
Gramm R, NRR/DIRS, 415-1010
References
Download: ML081010229 (7)

Text

Cross-cutting Issue Review Effort This review group included representatives from each of the regions, the Office of Enforcement, and the Office of Nuclear Reactor Regulation. The review evaluated implementation practices across the four NRC regions with regard to the assignment of cross-cutting aspects to inspection findings, evaluation of cross-cutting aspects in the assessment process, and the identification of substantive cross-cutting issues (SCCIs). The review group performed peer observations of regional inspection debriefs and regional mid-cycle assessments, performed a sample review of inspection reports, solicited feedback from the industry, and assessed historical inspection finding data.

The review determined that the regions are implementing the program in accordance with guidance in Inspection Manual Chapters (IMCs) 0612 and 0305. The review group identified that during the early stages of implementation there were some issues associated with clearly documenting cross-cutting aspects, however, there are indications showing improvement in this area. In addition, recent data is revealing that the differences between the regions on the number of findings with cross-cutting aspects are narrowing which is indicative of improved consistency among the regions. While there were some differences noted in how the regions prepared for and conducted the assessments, the differences were not significant and had no impact on the overall process.

While the results of this effort concluded that the regions are appropriately following the guidance in IMCs 0612 and 0305 and there were no significant issues identified, there were some recommendations to be considered to further enhance the program.

Cross-cutting Issue Review Recommendations and Lessons Learned Recommendations and Appropriate IMC Status lessons learned CI-1. The regions should be N/A Several regions have or are encouraged to consider considering expanding their conducting inspection debriefs inspection debriefs.

which involve both reactor divisions with attendance including staff as well as management.

CI-2. Revise IMC 0612 to IMC0612 In-progress provide additional guidance and examples for assigning and documenting cross-cutting aspects.

CI-3. NRR should continue IMC040 No changes needed.

their process of providing periodic refresher training to staff on IMC 0612 and 0305 as changes are made.

CI-4. Clarify that a cross- IMC0305 In-progress cutting theme needs to involve 1

four or more inspection findings with the same cross-cutting aspect (should not look for sub-cross-cutting aspects)

CI-5. Identified redundancy in IMC0305 In-progress the first two criteria for a substantive cross-cutting issue in the problem identification and resolution and human performance cross-cutting areas.

Palo Verde NRC Lessons Learned One of the major ROP safety culture enhancements was an extensive modification to Inspection Procedure 95003. The staff added guidance to the inspection procedure to describe how the NRC will evaluate a licensees third-party safety culture assessment and how the NRC will perform its own independent assessment of the licensees safety culture. The NRC issued the revised inspection procedure in October 2006, and it was used for the first time at the Palo Verde site in 2007. As part of the inspection procedure implementation, lessons-learned were identified. The staff is considering changes to the inspection procedure to redefine the primary focus of the NRC safety culture assessment to be determining the adequacy of the licensees third-party safety culture assessment methodology and implementation. If the staffs review of the licensees third-party assessment methodology is determined to be adequate, NRC safety culture assessment resources can be better targeted to focus on areas of identified weaknesses.

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Palo Verde Lessons Learned Recommendations Recommendation Appropriate IMC Status PV-1. Consideration should be given to considering all 13 safety culture components during In progress, working implementation of the baseline program. Additional to incorporate the criteria should be established for when to consider IMC 0305 other safety culture a cross-cutting theme for the safety culture components as cross-components of accountability, continuous learning cutting components.

environment, organizational change management, and safety policies.

PV-2. Consider revising IMCs 0305 and 0612 to allow inspectors to assign multiple cross-cutting Not adopting this aspects for each safety culture related cause recommendation, associated with a performance deficiency. If the Reinforcing existing result is an increase in the number of cross-cutting IMC 0612 flexibility to only aspects, then MC 0305 should be revised to raise IMC 0305 assign multiple cross-the criteria to satisfy the requirements for a cutting aspects for substantive cross-cutting issue. In addition, for unusual or complex sites with multiple units, consideration should be issues.

given to raising the criteria to satisfy the requirements for a substantive cross-cutting issue.

In-progress, working PV-3. Cross-cutting safety culture issues challenge to slightly modify NRC the ability of the NRC to reach accurate risk regulatory responses informed decisions and provide an appropriate to a repetitive level of regulatory oversight. Consideration should IMC 0305 substantive cross-be given to evaluating and developing more cutting issue. No assertive NRC actions (such as a direct input to the changes proposed to ROP action matrix) for repetitive or certain types of the ROP Action Matrix multiple substantive cross-cutting issues.

inputs.

PV-4. Consideration should be given to providing additional guidance in IMC 0609 on the acceptable IMC 0609 In-progress, working methods to be used to assess the additional risk IMC 0305 on amplifying the impact of findings with underlying causes that are IP95003 guidance.

associated with the safety culture components.

PV-5. Consideration should be given to adding In-progress working specific guidance in IP 95003 that describes the IP 95003 on amplifying the acceptable method to be used to perform the guidance.

cumulative risk assessment.

PV-6. Consideration should be given to revising IP 95003 to include an allowance to validate the results of the licensees root cause investigation in lieu of the NRC performing a separate root cause IP 95003 In-progress.

investigation. The NRCs completion of this activity should only occur if the licensees investigation is determined to be incomplete.

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PV-7. Consideration should be given to describing root cause analysis tools other than MORT that could be used to complete the collective review of IP 95003 In-progress.

the root causes. Additionally, it may be necessary to add a root cause specialist to the team to complete the review.

PV-8. The NRC should consider partnering with industry in an effort to develop a standardized IMC 0305 Considering this item.

safety culture assessment process and tools, IP95003 including a survey.

PV-9. Until an industry/NRC accepted standard is In-progress, intend to developed, the NRC should perform an retain elements to independent detailed analysis of the survey tool IP 95003 validate licensee and analytical techniques when evaluating a safety culture licensees safety culture assessment. assessment methods.

PV-10. Consider revising IP 95003 to provide the flexibility to initiate a variety of inspection In-progress, working responses consistent with the performance IP 95003 to provide flexibility for deficiencies at a particular facility. This should site situations.

include an evaluation of the existing IP 95003 boundary conditions.

In progress, plan to amplify outage PV-11. Consider revising IP 95003 to include an coverage and IP 95003 assessment of outage activities. sensitivity of the outage inspection burden on licensee.

PV-12. Consider revising IP 95003 to treat the activity as a fact finding to understand the depth In-progress, working and breadth of performance concerns. This IP 95003 to amend inspection includes the potential for greater use of unresolved approach.

items.

PV-13. Consideration should be given to In-progress, looking at establishing and assessing precursors as part of correlation of safety the baseline inspection program. These precursors IMC 0305 culture components should be assessed as part of the IMC 0305 with qualitative assessment process. precursors.

PV-14. Consideration should be given to developing innovative methods to assess the IMC 0307 Under consideration.

effectiveness of inspection program implementation.

PV-15. Consideration should be given to permanently changing the resident inspector staffing requirements at three unit sites to ensure IMC 0102 Under consideration.

an appropriate level of oversight is maintained.

(For a 3 Unit Site: 1 - Senior Resident Inspector, 3

- Resident Inspectors) 4

PV-16. Consideration should be given to providing additional guidance to supervisory and management personnel for the conduct of IMC 0102 Under consideration.

management site visits at facilities where only a few findings have been identified.

PV-17. Consideration should be given to adding one FTE per region to focus on initial and IMC 0102 Under consideration.

continuing training needs of the inspection staff.

PV-18. Consider revising IP 95003 to require implementation of the EP attachment and having IP 95003 Under consideration.

an EP inspector from another regional office perform the attachment.

PV-19. Consideration should be given to evaluating the implementation of the EP baseline inspection IP 95003 Under consideration.

program.

PV-20. IP 95003 boundary conditions (1, 3, and 5) should be reevaluated. For condition 1 consider adding flexibility to allow the NRC to oversee independent inspections performed by a third-party. Review consistency with having an independent third-party assess the licensees safety culture.

For condition 3 consider a revision to increase the flexibility of the procedure by allowing the use of unresolved items and a separate follow-up inspection to resolve the technical concerns (defer significance determination process evaluation). IP 95003 In-progress.

For condition 5 consider a revision to increase the flexibility of the procedure by considering the implementation of portions of the inspection procedure before the licensee has completed their third party safety culture assessment and root cause evaluation in order to promptly assess the depth and breadth of potential problem areas.

Additionally, consider a revision to allow for periodic NRC assessments during the performance of the licensees root cause analysis and third-party safety culture assessment.

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PV-21. IP 95003-02, Inspection Requirements, indicates that if the IP 95001 and IP 95002 supplemental inspections have not been performed, then the IP 95003 should include an assessment of the licensees evaluation of those issues. A revision should be made to note that the IP 95003 In-progress.

licensees evaluation of the IP 95001 and 95002 issues may not be complete at the time of the IP 95003 inspection. If so, the review of these issues should be included in the Confirmatory Action Letter.

PV-22. Almost all of the inspection requirements in IP 95003 are performed as part of the baseline inspection program. However, IP 95003 indicates that a duplication of inspection efforts should not IP 95003 In-progress.

occur. A revision should be made to delete a statement in IP 95003 to prevent duplication of other inspection efforts.

PV-23. To more efficiently integrate safety culture and inspection results, it may be more appropriate to embed some safety culture components in the key attributes. The additional safety culture component assessments should focus on those areas where implementation of the inspection IP 95003 In-progress.

program yields limited results. For example, most problem identification and resolution aspects can be evaluated using traditional inspection program techniques. Therefore, limited safety culture assessment interviews and focus groups are needed to assess this area.

PV-24. The requirements and guidance in section 02.07 for conducting the safety culture portion of IP 95003 should be re-evaluated. If the NRC determines that the licensees third-party assessment was appropriate, then there should be no need to conduct an independent assessment of all 13 safety culture components. The NRCs assessment should determine which, if any, of the 13 components have not been adequately IP 95003 In-progress.

addressed by the third-party assessment and which, if any, of the components are not likely to be addressed by the IP 95003 key attributes. The NRC should then implement safety culture assessment activities to address the remaining components that are expected to have insufficient data to meet the objectives.

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PV-25. Re-evaluate sections 02.07 and 02.08 to only include the specific inspection requirements.

IP 95003 In-progress.

All other items should be moved to the guidance section.

PV-26. Section 95003-03 for just-in-time training should be better designed to meet the needs of the inspection teams. The training should include, in IP 95003 In-progress.

part, performance issues at the facility, root cause refresher training, administrative issues, and the conduct of the inspection.

PV-27. Regarding team staffing, a qualification program for safety culture assessors should be institutionalized in a manual chapter. Each region should be expected to maintain a cadre of Level 2 safety culture assessors that are capable of implementing most of the IP 95003 inspection requirements. Validation of third-party safety IMC TBD Under consideration.

culture assessment tools and methods requires an additional skill set, and can be performed by headquarters personnel or contractors. These skills may not be needed in every case if the NRC and industry develop and implement a standardized safety culture assessment tool and process.

PV-28. At a minimum, a senior reactor analyst should be required to participate in the final onsite inspection week in order to collect all of the data needed to perform a collective risk assessment of the performance deficiencies and assist in IP 95003 Under consideration.

collecting the data necessary to evaluate potentially significant inspection findings. The most desirable option would be to have a senior reactor analyst lead one of the sub-groups and perform the analyst functions as a collateral responsibility.

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