ML19179A105

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Charter for Effectiveness Review of the Cross-Cutting Issues Program
ML19179A105
Person / Time
Issue date: 07/09/2019
From: Alex Garmoe
NRC/NRR/DIRS/IRAB
To:
Garmoe A, NRR/DIRS, 301-415-3814
References
Download: ML19179A105 (5)
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Text

Cross-Cutting Issues Program Effectiveness Review Team Charter I. Background The NRC identifies a cross-cutting issue (CCI) to inform the licensee that the NRC has a concern with the licensees performance in the cross-cutting area and to encourage the licensee to take appropriate actions before more significant performance issues emerge. Cross-cutting areas contain the fundamental performance characteristics that extend across all of the ROP cornerstones of safety. These areas are human performance, problem identification and resolution, and safety conscious work environment (SCWE). Within each cross-cutting area are aspects of performance related to that cross-cutting area. The cross-cutting aspects (CCAs) are described in IMC 0310, Aspects Within Cross Cutting Areas. The NRC assigns CCAs to inspection findings, in accordance with IMC 0612, Issue Screening. The NRC reviews CCAs for cross-cutting themes and potential CCIs, in accordance with IMC 0305, Operating Reactor Assessment Program, to provide licensees the opportunity to address performance issues before they result in more significant safety concerns. Although the presence of CCAs or the assignment of a CCI may be indicative of a potentially degraded safety culture, the NRC draws conclusions about safety culture based on the results of licensee and NRC safety culture assessments conducted by qualified staff, not based on the presence of CCAs or CCIs.

The staff was initially directed in SRM-SECY-04-111, Recommended Staff Actions Regarding Agency Guidance in the Areas of Safety Conscious Work Environment and Safety Culture, to develop a Substantive CCI (SCCI) program. The SCCI program was introduced with the June 22, 2006, update to IMC 0305 (ML061520397) and initially included 27 CCAs, not including 10 CCAs associated with safety culture that were reserved for use during supplemental inspections. As initially designed, an SCCI existed when there were more than three current findings with the same CCA (or one in the SCWE area) and NRC is concerned with the scope of licensee efforts in addressing the issue. In 2013, the CCAs were revised to align with industrys safety culture language and the Commissions safety culture policy statement, which resulted in a reduction from 27 to 23 CCAs, not counting 12 CCAs associated with safety culture that were reserved for use during supplemental inspections. The SCCI program was otherwise unchanged with this update.

On February 18, 2014, an independent review of the ROP was completed, as directed by the Commission in the SRM for SECY-12-0081. The report identified eight recommendations for improving the ROP, including a recommendation that the staff perform a comprehensive analysis to determine whether the use of CCIs and safety culture provides regulatory value in terms of licensee safety performance for the resources expended. The SCCI program was revised in 2015 (Change Notice (CN)15-005, ML15089A315) and renamed the CCI program.

This program revision defined a cross-cutting theme as having 6 findings in a specific aspect or reaching backstops of 20 total findings in the human performance area or 12 total findings in the PI&R area. A CCI (which replaced the concept of an SCCI) was defined as a theme being present for three consecutive assessment periods (end of cycle or mid cycle). The same 23 CCAs (and 12 safety culture CCAs reserved for use during supplemental inspections) were carried forward.

The changes implemented by CN 15-005 represented a significant increase in the threshold for opening a CCI. There were no CCIs identified for any plant from the time CN 15-005 was issued in April 2015 until the 2018 mid-cycle assessment, when a SCWE CCI was opened for Watts Bar based on issuance of a chilling effect letter.

II. Purpose The purpose of this effectiveness review is to review the CCI program and the changes made to the program in 2015 to determine whether the program is achieving its objective and provide recommendations on any necessary program changes.

III. Tasking A. Review ROP documents describing the CCI program to ensure a clear understanding of the basis for the CCI program and how it is implemented.

  • IMC 0310 B. Review revisions of ROP documents describing the initial SCCI program prior to the 2015 program changes to ensure a clear understanding of how the SCCI program was previously implemented.
  • RIS 2006-13 C. Review documentation forming the basis for the 2015 changes to the CCI program, including:
  • Cross cutting issue threshold analysis (not in ADAMS)
  • Recommendations to change the SCCI process from the previous working group (ML14309A612) to understand the basis for the changes D. Review the Case File for Grand Gulf DPO-2017-009 (ML19043A950).

E. Review ROP Enhancement recommendations and documentation dispositioning the recommendations associated with the CCI program, specifically recommendations 1E, 2B.4, 78, 197, 248, 338, and 627.

F. Review historical data on SCCIs (pre-2015 changes) and CCIs (post-2015 changes).

Compare this information with other assessment data such as total number of assessment inputs, plants in various Action Matrix columns, and any other data the effectiveness review team finds relevant. Identify plants before 2015 that would have tripped the new criteria and plants after 2015 that would have tripped the old criteria.

Identify when plants met a cross-cutting theme under the new criteria and whether they ultimately tripped the CCI threshold or by how much they missed the threshold.

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G. Use public meetings, such as ROP public meetings in which the CCI program or the CCI program effectiveness review is an agenda topic, to seek feedback on the CCI program and communicate prospective changes.

H. Compare licensee placement in the Action Matrix vs presence of a cross-cutting theme (using current criteria and original criteria). Consider program improvements to have thresholds that effectively identify licensees exhibiting poor or declining performance.

I. Discuss with regional staff and management their experiences with the SCCI and CCI programs to identify examples where it has led to positive outcomes and where it hasnt, and why.

J. Seek internal and external stakeholder views about the effectiveness of the CCI program and recommended changes. External views may be solicited via the monthly ROP public meetings. Include applicable internal perspectives provided via the NRC Futures Jam.

K. Determine whether changes should be made to the CCI program objectives, and determine changes needed to ensure intended objectives are achieved. If so, develop specific recommendations including pros and cons of proposed changes.

L. Develop a draft report documenting the teams efforts, conclusions, and recommendations. An example of an effectiveness review report is the IFRM Effectiveness Review (ML18123A319).

IV. Team Leader Functions

  • Schedule and lead team meetings
  • Ensure action items are identified and tracked
  • Circulate draft products for members to review
  • Provide periodic status briefings to the NRR/DIRS Director or Deputy Director of the status of the effectiveness review V. Team Membership
  • Nick Hobbs, RII/DRP/RPB5/BFN
  • Harry Freeman, RIV/DRS/IPAT VI. Duration This charter will remain in effect until the effectiveness review report is issued, which is expected by the end of calendar year 2019.

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VII. Level of Effort Members are expected to review reference information, participate in periodic teleconference meetings, and complete action items assigned at team meetings. Travel might be necessary for some team meetings. In addition, team members are expected to dial in or attend public meetings in which the cross-cutting issues program or the effectiveness review will be discussed.

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SUBJECT:

CROSS-CUTTING ISSUES PROGRAM EFFECTIVENESS REVIEW TEAM CHARTER JULY 9, 2019 DISTRIBUTION:

MFerdas, RI JHeisserer, RII AMStone, RIII RKellar, RIV RGibbs SWalker GBowman HJones ADAMS Accession No.: ML19179A105 *via e-mail OFFICE NRR/DIRS/IRAB

  • NRR/DIRS/IRAB NRR/DIRS NAME AGarmoe AMasters CMiller DATE 6/26/19 7/3/19 7/9/19 5
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