ML18207A517
| ML18207A517 | |
| Person / Time | |
|---|---|
| Issue date: | 08/01/2018 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, NRR/DIRS, 415-2259 | |
| References | |
| Download: ML18207A517 (8) | |
Text
Proposed Enhancements to the Reactor Oversight Process Reactor Oversight Process Public Meeting July 19, 2018 1
Enhancing the Reactor Oversight Process NRC has a number of initiatives ongoing to make the ROP more effective and efficient. Examples include:
- Improvements to the inspection report development process
- Previously-discussed initiative to improve the minor/MTM component of the issue screening process
- Work to enhance the NRCs engineering inspection program (SECY to EDO in August)
DIRS received input from stakeholders as part of the ongoing agency initiative associated with transformation:
- ~60 recommendations from the internal stakeholders related to potential enhancements to the ROP
- NEI publication and NRUG letter with proposals to improve the ROP
- Expect follow-up letter from the industry with more refined suggestions for ROP enhancement (e.g., specific problems with focused proposals) 2
Internal Stakeholder Feedback The Transformation Team provided DIRS with consolidated stakeholder feedback related to ROP transformation.
The feedback generally fit into several categories:
- Changes to organization and staffing supporting oversight, primarily regional changes
- Changes to frequency of inspections and focus of inspection procedures
- Changes to make performance indicators more effective
- Changes to the various components of the assessment process
- Changes to make the enforcement program more risk-informed
- Changes to streamline or eliminate inspection reports No assessment was done of the proposals; the input to DIRS consisted of direct feedback provide by NRC staff.
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4 NEI Feedback NEIs March 2018 publication, A Framework for Regulatory Transformation, provided recommendation in many areas.
One stated objective to make the ROP more focused on issues with risk and safety significance, leading to timelier decision-making.
Specific recommendations for ROP change include:
- Eliminate White findings
- Development of a risk-informed compliance process, where low risk compliance issues can be evaluated and addressed by the licensee without direct NRC inspection
- Eliminate the use of SPAR models
5 NRUG Feedback NRUGs May 2, 2018, letter proposes a paradigm shift, where factors such as prompt corrective action are more fully considered in the response to an inspection finding.
NRUG provided some suggestions on how this approach could be implemented, to serve as a starting point for discussion:
- Provide credit for licensee self-assessment in the oversight program
- Better communicate the actual risk of GTG findings
- Eliminate White findings
- Allow GTG findings to roll-off immediately after a successful supplemental inspection
- Modify the EP SDP to more fully consider actual vs. potential consequences
Possible ROP Enhancements Based on Feedback Improvements to the inspection program:
- Extend the work done to improve the engineering inspection program to assess other areas
- Consider crediting licensee self-assessments in the inspection program
- Enhance PIs (e.g., augment existing NRC PIs with a subset of INPO PIs);
reduce inspection if performance meets an established standard Modifying the treatment of White findings:
- Consider combining Column 1 and 2 or establish a scaled-back inspection approach for White findings that dont result in a licensee moving into the degraded cornerstone column
- Change the way the NRC messages White findings (e.g., press releases)
- GTG findings would no longer be Action Matrix inputs once the supplemental inspection is completed, even if it takes places in less than four quarters; similarly, PIs would remain inputs until the supplemental inspection is completed Complete the ongoing evaluation of the EP SDP and make improvements, if needed.
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Challenges This work is not budgeted. The add/shed/defer process would need to be used to assess and implement the recommendations.
A number of competing, high-priority activities are ongoing, such as:
- Replacement Reactor Program System/auto-report generator initiative
- Support for NRC backfit initiative
- Extensive international support
- Resident inspector recruitment and retention initiative
- Resolving Red metrics from ROP self-assessment Many of the recommendations are complex, with the potential for unintended consequences if not implemented properly.
Significant outreach will be needed with both internal and external stakeholders before moving forward with any of the recommendations.
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Next Steps Industry to complete development of problem statement(s) and submit proposed enhancements to the NRC.
Assess and resolve NRC resource challenges.
Establish working group(s) to obtain stakeholder input, evaluate proposals, develop recommendations.
Establish recurring discussion at monthly ROP public meetings, with separate focused public meetings on specific ROP enhancements.
Commission approval will be needed for any significant changes to the ROP, per Management Directive 8.13.
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