ML17271A266

Enclosuitaac Demonstration Project Action Plan

ML17271A266
Person / Time
Issue date:	09/29/2017
From:	Human Performance, Operator Licensing & ITAAC Branch
To:
Gaslevic J, NRO/DCIP
Shared Package
ML17263A152	List: ML17261A375 ML17271A266
References
Download: ML17271A266 (6)

Text

Enclosure 1 ITAAC Demonstration Project Action Plan Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

Weekly Public Meetings

1. Utilize weekly public meetings to facilitate This recommendation has been Lead = DCIP/HOIB Complete resolution of critical issues associated with ITAAC implemented. Staff is currently using the Support = DNRL closure notification (ICN) and uncompleted ITAAC public meetings to effectively discuss and closure notification (UIN) reviews, including items address ICN and UIN issues.

such as the intent of an ITAAC, ICNs with challenges, methods for resolution of issues, and NRC-REG-103, Inspections, Tests, Analyses, 1 Qtr 2018 informed decision making. and Acceptance Criteria (ITAAC) Closure Verification Process, will be updated and In addition, establish standing agenda items publicly released to include process and the during the weekly public meeting to discuss purpose of meeting.

expected ICN submittal workloads to allow early notification of resource needs and critical process points.

Increase the frequency of public meetings to accelerate the resolution of emerging ITAAC closure issues as the surge approaches.

Clarity in Existing Industry Guidance

2. Develop an FAQ-type process to provide a Assess existing guidance and determine if NRO/DCIP/HOIB 4 Qtr 2017 forum to document discussions and resolutions there is still a need for a new process to deal of issues associated with the content of ICNs and with generic issues associated with the UINs, which may be due to gaps in existing content of ITAAC notifications, or if issues will guidance or interpretation discrepancies. be dealt under the public meeting process in Recommendation 1.

Document staff assessment. 1 Qtr 2018 1

Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

3. Work with stakeholders to identify complex Update and publicly release NRC-REG-103 to NRO/DCIP/HOIB 1 Qtr 2018 ITAAC issues by reviewing early submittals of capture definition of complex ITAAC, how uncompleted ITAAC notifications and develop complex ITAAC are assessed, and how issues clear expectations for the content of the will be resolved.

associated ICN submittals. This effort will include identifying when complex ITAAC will be completed during the construction schedule.

NRC Processes Guidance Enhancement

4. Revise applicable NRO office instructions to Update and publicly release NRC-REG-103 to NRO/DCIP/HOIB 1 Qtr 2018 ensure lessons learned and enhancements for the capture:

ICN process, identified during this demonstration project, are institutionalized. The revision should 1) lessons learned and enhancements to the include, but is not limited to, the development of ITAAC review process that enable staff to the criteria of when technical reviewer referral is resolve ITAAC closure issues consistently and needed during the reviews of ITAAC notifications, efficiently the evaluation of the requirement of completing half of targeted ITAAC before completing 2) the evaluation of the requirement of verification of non-targeted ITAAC within an completing half of targeted ITAAC before ITAAC family, and the involvement of technical completing verification of non-targeted staff for all ITAAC notifications related to security ITAAC within an ITAAC family and emergency-preparedness.

3) criteria for including technical reviewer Make the revised NRC office instruction NRO- during reviews of ITAAC notifications REG-103 publicly available to give stakeholders insight into the NRCs ITAAC notification review process.

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Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

5. Enhance NRC processes, including associated Complete each of the following items for NRC RII governing documents, communications, and processes TARs, URIs, ITAAC inspection training, to ensure timely identification and findings, allegations, and IPCNs.

resolution of concerns or findings material to ITAAC, such that ITAAC inspection results support 1) Pilot process enhancement for two topics:

key activities and milestones in the ITAAC closure Inspection Inputs and ICN Inspection verification process. Schedule Accountability, in order to identify lessons learned and incorporate into the

a. Enhance/develop, as applicable, the following Action Plan for other processes.

processes: technical assistance requests (TARs),

unresolved items (URIs), ITAAC inspection a. Develop timeliness metrics for Inspection Complete findings, allegations and petitions, and ITAAC Inputs and ICN Inspection Schedule post closure notifications (IPCNs). For TARS, Accountability.

consider the frequency of performing this b. Execute pilot and evaluate effectiveness 4 Qtr 2017 process; the timeliness of TAR processing; and of metrics and process enhancements.

interactions with licensees for visibility purposes. c. Finalize metrics from pilot lesson learned. 4 Qtr 2017

d. Incorporate lessons learned into the

b. For inspection findings, consider enforcement development process of additional 4 Qtr 2017 actions and internally and externally disputed timeliness metrics (Step 2).

findings. Consider which NRC process activities, if any, can be done in parallel with the evaluation 2) Develop process enhancements for the of an ITAAC technical concern. following areas: TARs, URIs, ITAAC inspection findings, allegations and petitions, and IPCNs.

a. Develop timeliness metrics for the above 4 Qtr 2017 areas.

b. Execute and evaluate effectiveness of 1 Qtr 2018 metrics and process enhancements.

c. Finalize metrics from lesson learned. 1 Qtr 2018

d. Incorporate lessons learned into the development process of additional 1 Qtr 2018 timeliness metrics, as determined.

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Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

3) Determine if additional guidance is needed for each process affecting ITAAC closures. 2 Qtr 2018 Create working level guidance (i.e. Desktop Guides) for RII and NRO staff. Revision of guidance documents, such as inspection manual chapters (IMCs) and inspection procedures (IPs), will be completed under the regularly scheduled update for each of those documents.

4) Develop and implement change management plan for training needs and 2 Qtr 2018 communication plan, which includes follow up public meeting, with the licensee and the public.

Performance Dashboards

6. Create an integrated, highly visible, internal, Develop performance dashboards to track NRO/DCIP/HOIB 4 Qtr 2017 color-coded performance dashboard to track the the status and timeliness of ICN reviews and and RII status of each step for ICN reviews and inspection ITAAC inspections based on program metrics.

process for early identification of ITAAC closure related issues for management attention and Develop performance dashboards for 4 Qtr 2017 resolution. inspections that affect ITAAC closures to highlight issues based on program metrics.

Specific process steps to measure should include:

• The status of each step for ICN reviews.

• Key aspects of the inspection process, including the timeliness of report issuance, inspection initiators, and inspection outcomes 4

Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

• Potential inspection scheduling or resource issues Inspection Scheduling

7. Determine the most efficient location and time Incorporate scheduling process lessons RII 1 Qtr 2018 for inspections. Continue to focus on short- learned into Desktop Guide(s) including duration construction activities, such as installing decision making on how to schedule different the reactor vessel, which are unlikely to be types of inspections.

repeated for additional inspection opportunities.

Produce a schedule of pre-op test procedure 2 Qtr 2018 Additionally, verify that test procedure reviews and tests to verify inspections are inspections are scheduled when procedures are scheduled ahead of tests.

issued and available versus when the tests are being performed.

Timeliness of Inspection Reports

8. Establish timeliness requirements for Review existing process(s) for inspection Lead = DCIP/CIPB 1 Qtr 2018 inspection disposition including inspection report timeliness requirements, including Support = RII completion in CIPIMS and inspection report dispositioning inspection findings for issuance to support the ITAAC surge and the 10 potential efficiencies.

CFR 52.103(g) finding.

Create or revise working level guidance (i.e. 2 Qtr 2018 Desktop Guides) for RII and NRO staff to capture efficiencies for inspection report timeliness. Revision of guidance documents, such as IMCs and IPs, will be completed under the regularly scheduled update for each of those documents.

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Lead and Due Date Recommendation Detailed Action Items Supporting Roles (Calendar Year)

Maintain Qualified Staff

9. To ensure continued ICN review and inspection Update and publicly release NRC-REG-103 to DCIP/HOIB 1 Qtr 2018 capacity, cross-train additional staff to support capture the cross-training procedure, ICN workflow capacities and ITAAC inspections. including developing a metric to track amount of staff cross-trained and number of For inspector qualification, the NRC will ICN reviewed in a given year to maintain incorporate construction inspector training into proficiency in ICN reviews.

IMC-1245.

Construction inspector qualification will be RII Complete incorporated into IMC 1245 Appendix C-15 Organizational Structures

10. Establish a temporary organizational Develop and capture in a memorandum the NRO 1 Qtr 2018 structure with senior executive leadership criteria for establishing a temporary approximately 12-months before projected fuel organization to oversee the ITAAC closure load. This organization would oversee and verification process.

coordinate the ITAAC closure verification process to ensure appropriate decision making and the prompt identification and resolution of issues.

External Stakeholders

11. Create a message map on key aspects and Develop a message map that includes key NRO/DCIP 4 Qtr 2017 updates of the ITAAC process for external aspects of the ITAAC process.

stakeholders. Update this message map on a quarterly basis. Update and publicly release NRC-REG-103 to 1 Qtr 2018 capture that the message map will be reviewed and updated on a quarterly basis.

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