ML19086A122

ROP Enhancement Presentation for 3-27-2019 Public Meeting

ML19086A122
Person / Time
Issue date:	03/27/2019
From:	Russell Gibbs NRC/NRR/DIRS/IRAB
To:
Govan T
References
Download: ML19086A122 (23)

Text

Reactor Oversight Process ROP Enhancement Project Update ROP Public Meeting March 27, 2019

Introductions and Opening Remarks 2

Agenda Time Topic Speaker 1:00 pm Introductions/Opening Remarks NRC Management and Industry 1:15 pm ROP Enhancement NRC Staff 2:00 pm Stakeholder Feedback External Stakeholders 2:30 pm Open Discussion All 3:15 pm Next Steps NRC Staff 3:30 pm Questions and Comments Members of the Public 3:45 pm Closing Remarks NRC Management and Industry 4:00 pm Meeting Adjourned 3

Meeting Purpose

• To update industry and public on the status of the ROP enhancement project

• To hear industry and public views and feedback on three major ROP enhancement themes presented 4

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Background===

• Received 72 recommendations for enhancing the ROP from NRC Transformation initiative - August 13, 2018

• Received 27 recommendations provided to NRR by NEI

- September 19, 2018

• Discussions at Operating Reactor Business Line and NRC Transformation Team Commission meetings - fall 2018

• ROP enhancement project initiated - October 2018

• Goal is to provide a SECY paper to the Commission -

June 2019 5

ROP Enhancement Goals

• Make the ROP more risk-informed and performance-based

• Further improve consistency with the NRCs Principles of Good Regulation

• Improve the ROPs efficiency and effectiveness 6

Objectives

• Focus NRC oversight on issues of higher safety significance

• Enhance the Significance Determination Process (SDP) through improved procedures, risk assessment tools and communications

• Improve efficiency and effectiveness of inspection program

• Improve communications between NRC and nuclear industry 7

Project Infrastructure

• NRR office director is executive sponsor, NRR/DIRS is management team

• Recommendations binned into eight areas (themes)

- Each theme assigned a manager and SME(s)

• Developed extensive project management tools

• Held numerous internal and external stakeholder meetings

• Developed internal SharePoint site and external website https://www.nrc.gov/reactors/operating/oversight/rop-enhancement.html 8

Guiding Principles

• Leveraging ROP self-assessment process

• Maintaining/improving upon ROP strengths

- objective, predictable, transparent

• Developing a strong basis for important changes

• Obtaining stakeholder feedback

• Taking into account alternative views

• Not a one and done effort 9

Strong Regional Involvement

• Collaboration through pre-existing initiatives (EP, security, RP, engineering inspection work)

• Inspector seminar/inspector newsletters

• Extensive regional engagement

• Regional Advisory Panel (RAP) established

- Jimi Yerokun, Joel Munday, Mohammed Shuaibi, Tony Vegel 10

Commission Paper Content

• Main paper to include those proposals that require Commission approval and notification

• Enclosures for each thematic area to include supporting information, completed actions, and longer-term actions

• Analyses to support changes such as historical industry performance, nuclear safety trends, and supporting program data Reference SRM/COMSECY-16-022 11

Three Major Themes in Paper

• NRC response to White inspection findings

• Baseline Inspection Program taking into account nuclear safety trends since ROP began

• Significance Determination Process (SDP) improvements 12

Major Theme 1 - NRC Response to White Findings

• Press release guidance for White findings

• White and Yellow finding labels to low and moderate significance, respectively, and conforming changes to Action Matrix such as:

- communications to State and local governments

- Column 2 language to align with finding labels

• Supplemental inspection for White findings

• Four quarter requirement for GTG findings

- option to revise treatment of GTG PIs 13

Major Theme 2 - Baseline Inspection Program

• As part of the review staff considered:

- Risk Insights (DRA and regional SRA inputs)

- Plant Performance

- Results from IMC 0307B biennial Self Assessment

- Feedback from all levels of regional staff and management

- Recommendations evaluated by experienced SRIs, RIs, regional inspectors and HQ IP Leads

- Adjustments based on comments by the Regional Advisory Panel (RAP) 14

Major Theme 2 - Baseline Inspection Program

• Inspectable areas unaffected

• Optimize Baseline Inspection Program

- Adjust inspection samples/hours for numerous IPs

- Combine certain IPs for efficiency (surveillance test and PMT)

- Modify ALARA inspection based on continuous decline in occupational exposure

- Change frequency of PI&R team inspections from biennial to triennial 15

Major Theme 3 - SDP Improvements

• Risk-inform the EP SDP using defense-in-depth philosophy and distinguishing significance of certain planning standards

• Revise approach to updating IMC 0609, Appendix M

• Incorporate IMC 0609, Appendix O (Mitigating Strategies SDP) into to IMC 0609, Appendix A (At Power SDP)

• Review current SDP and IFRM process to identify additional opportunities to enhance interactions with licensees 16

Commission Approval Needed

• Eliminate the 4 quarter requirement for GTG findings

- option to revise treatment of GTG performance indicators

• Optimize the Inspection Program

• Risk-inform the emergency preparedness SDP Reference SRM/COMSECY-16-022 17

Longer-Term Activities

• Evaluate revisions to performance indicators

• Perform holistic review of PI&R inspections

• Re-evaluate the Cross-Cutting Issues Program

• Optimize Independent Spent Fuel Storage Installation inspections

• Optimize radiation protection inspections

• Evaluate SDP infrastructure improvements

• Assess additional actions identified in emergency preparedness focused self-assessment 18

Out-of-Scope Recommendations

• Recommendations associated with regional structure and organization

• Resolution of low risk compliance issues

- Evaluate as part of separate working group

• Backfit and licensing basis recommendations

- Resolve through broader agency backfit initiative

• Proposals to streamline inspection reports

- Address through ongoing ISTAR initiative

• Other miscellaneous recommendations evaluated through ROP self-assessment 19

Stakeholder Feedback 20

Open Discussion 21

Next Steps

• Commission paper concurrence (April - June 2019)

• Implement Commission approved recommendations

• Assess actions for next ROP enhancement phase

• Perform a lessons learned on the ROP enhancement project

• Meet with industry, as needed, during routine ROP monthly meetings 22

Closing Remarks 23