ML19298A119

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Slides Nov 7 2019 TIA (TAR) Industry Public Meeting - NRR-COM-106 Revitalization
ML19298A119
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Issue date: 11/07/2019
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Division of Operating Reactor Licensing
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NRR-COM-106 Revitalization TAR Technical Assistance Request TIA Task Interface Agreement Office of Nuclear Reactor Regulation (NRR)

Category 2 Public Meeting with NEI and Industry Table-top Discussions November 7, 2019

AGENDA Opening Remarks.Division Management, NRR, Division of Operating Reactor Licensing (DORL)

Staff Presentations.. NRR

COM-106 Program Revitalization TIA (TAR)

Risk-informing Modernized Decision-making Other Key Drivers Project Status 3-step, graded risk-informed approach proposed Program rebranding to TAR to align with NRO/NMSS NRR/NRO program components merge underway 3

Revitalized and Merged COM-106 Restructured as a fact gathering exercise to inform decision-making No agency action or decision taken within TAR Applies effort commensurate with the significance of the issue Merged TAR Components New Reactors Operating Reactors Construction TARs Merged Revitalized TIA Process (NRO COM-108) SharePoint (NRR COM-106)

Leverage current process Site (internal) Major overhaul Refined templates New templates and tools 4

Industry Recommendations on TIA Process*

Operating Reactors Increase Process Rigidity Greater Emphasis on Backfit Establish Exit Criteria for Low Safety Significance Issue Resolution Include an Appeal Process Eliminate Pre-decisional Consideration Enhance Communication Enhance TIA Coordinator Position

  • Inputs received in public meetings on Feb. 21, and March 19, 2019 5

TIA Program Challenges

1. Timeliness
2. Effectiveness Effort on low safety significant issues Delayed hand-offs to other processes Issues outside the scope of the TIA Lack of early and/or inconsistent alignment Inconsistent licensee engagement 6

New Graded Approach to Efficient and Effective Issue Scoping, Routing and Resolution

  • Boosted collaboration with requestor
  • Enhanced 3 licensee Safety engagement at Significance every step 2 1 IN-DEPTH REVIEW SCREENING AND Unresolved INTAKE EVALUATION question(s) from routine TAR

~ 8 hr. goal ~ 30 day goal

Response

processes Memo Intake forms TAR Screening and TAR referral, Evaluation Results response or Memorandum recommendations

  • Early alignment: Integrated Team Actions/
  • Diverse facts: OGC on board early Decisions in
  • Rigor in scoping/ framing questions Routine Processes 7

Internal WG Table Top Exercises Key Insights ROP LB Standing Hypothetical Operating Reactors Examples Used examples only COM-106 IMC 612 Intake TAR Review Template Team Table Top B Table Top A Intake + Table Top C LSSIR and TAR Screening and In-depth Review Interface Evaluation Safety Significance Determination Integrated Fact-based Worksheet Team Response LSSIR Tools Collaboration Licensee Engagement Early safety significance

  • Systematic gathering of facts Informing the licensee at the screening can help refocus (including licensee facts) can kick-off meeting about the TAR agency resources enable timeliness and progress and facts of the issue effectiveness in consideration can provide an
  • Requestor on board can help opportunity for the licensee to effective framing of questions engage further if needed
  • Focused integrated team 8 collaboration can help make timely recommendations

Safety Significance Considerations Operating Reactors 9

Featuring LSSIR Principle within TAR and ROP ROP issue of IMC 612 Is it of very Yes Inspection Public concern LSSIR low safety durable Criteria Disposition:

report per related to LB* significance document No or IMC 611 standing applicable per IMC 609? no further Indeterminate regulatory action and met Actions or Decisions by ROP NRR-COM-106 TAR Acceptance Criteria Met?

TAR Process Screening Intake and In-depth Review Phase Evaluation Phase Phase Facts Please Safety Significance Determination TAR If issue is of very low safety significance and of indeterminate LB Recommend-standing, it may be recommended for no further action ation 10 Non-public

  • LB- Licensing Basis document

New: Safety Significance Determination Tool Integrated (In Screening and Evaluation) Decision-making 11

Concepts of the Safety Significance Determination

  • Each step references a set of existing guidance options
  • A general preference is stated to promote consistency Wrap-up:
  • Based on the totality of the foregoing information, and from the perspective of

... whether the agency should expend significant additional resources investigating this issue (vice other issues), document whether the issue has apparent safety significance in each of the assessed areas.

  • If one or more elements has elevated significance, the issue on-the-whole may still be of very low safety significance (engage the integrated team)
  • The above assessment should reflect a consensus between the risk analyst and the topical area subject matter expert 12
  • Brief out to the integrated team

Concepts of the Safety Significance Determination (Continued)

Topic Item Outcome Key uncertainties not otherwise considered

  • Item #1;
  • Item #2 Safety significance summary The change in risk is very low/small Yes / No /

Indeterminate Adequate safety margin is retained Yes / No /

Indeterminate Sufficient defense-in-depth is maintained Yes / No /

Indeterminate There is adequate opportunity for feedback / Yes / No /

monitoring (or sufficient alternative means have Indeterminate been considered)

On the whole, the issues safety significance Very low /

appears to be: elevated /

indeterminate Were the issue to be subject to backfit criteria Yes / No /

(NUREG/BR-0058), the issues significance would Unknown likely meet these criteria.

Potential additional actions Evaluation shared with Regional SRA for relevance Yes / No / NA to other risk-informed evaluations for this facility?

SPAR Model Feedback Form submitted for potential Yes / No / NA adjustment of the baseline model?

13

Example of the Safety Significance Determination

  • Internal tabletop executed for a real issue applied to a different plant
  • Risk analyst/SME chose the following approaches:
  • Scoping PRA assessment
  • Risk triplet for safety margin
  • No direct opportunity for feedback identified
  • Potential relevance of condition to SPAR and SRA identified
  • Concluded that the issue was of very low safety significance; integrated team agreed 14

COM-106 Revitalized TIA (TAR) Process Operating Reactors (Note: All information on the slides are in Preliminary Draft form) 15

TAR BLOCK DIAGRAM From routine processes Unresolved question TAR Process If effort not commensurate with safety significance NRR COM-106 and other criteria met Refer to alternate process (e.g., backfit)

Recommend no further Resolution or Response regulatory action 16

FLOW CHART: TAR INTAKE PHASE Pre-intake TAR Coordinator informs Informal Discussions requestor & records in TAR SharePoint site Resolution &

Response

TAR Coordinator and Initiation of formal TAR NRR requestor complete (by requestor BC/ staff) with Pre-screening Path intake form and Intake form submission to and intake taken Requestor Referral TAR Coordinator discussions to Screening management

& Evaluation authorization sought Referral to alternate Licensee engagement by Construction TAR process requestor as needed Process (See flow chart in Appendix B) TAR Coordinator Requesting Office division informs requestor & management authorization records in TAR SharePoint site Screening and Evaluation Phase Initiation 17

FLOW CHART: TAR SCREENING AND EVALUATION PHASE Licensee engagement, if From relevant Screening &

Evaluation Safety Significance Resolution/

Initiation Determination Response and Close TAR Scoping and Recommend IT Screening, rigorous framing Stand-up no further Scoping and questions with action and Integrated iterations Evaluation Close TAR Team (IT) meetings or calls Routing Screening/

Evaluation for referral or resolution Elevate for disagreements IT Screening and Evaluation results Documentation Referral to Referral to In-depth alternate review phase with process and acceptable questions Close TAR Inform routine process and close TAR as appropriate TAR Coordinator notifies requesting office division management and In-depth review 18 initiation occurs

FLOW CHART: TAR IN-DEPTH REVIEW PHASE 19

Program Overview- TAR Issues should be resolved in the most efficient manner possible (e.g., informal discussions within routine processes at staff level)

TAR is not a routine process and is not intended to replace routine processes When routine channels are exhausted, TAR - a formal mechanism, may be invoked TAR should be viewed as an extension of the primary regulatory process it serves; at the same time TAR is NRRs program to serve NRC internal organizations (e.g., a region with a URI request in the inspection process) to address unresolved questions timely and effectively with an effort commensurate with the significance of the issue The TAR process should engage the licensees early and throughout the TAR process, as relevant to the issue and to the process the TAR serves 20

TAR Pre-screening (as a Pre-TAR or a key Intake Activity)

LSSIR Considerations (e.g., issue met new licensing basis and safety significance disposition criteria in IMC 612)

The NRC staff has previously expressed a position regarding the issue and it is applicable to the particular question The question or concern relates to another process and could be referred accordingly (e.g., backfit, generic implications, differing professional opinion, legal interpretations etc.)

Choosing a more efficient process of answering the question (e.g., would rely on a licensees or vendors evaluation, staff informal resolution, etc.)

21

TAR Acceptance Criteria (General) Plant Specific Issues only!

Issues Outside TAR Process:

Decisions or actions from TAR results, response or recommendations Enforcement actions Generic issues or concerns Backfit issues Non-concurrence or Differing Professional Opinion process 22

TAR Acceptance Criteria (Continued..) Plant Specific Issues only!

Screening and Evaluation Phase Acceptance Criteria Completed Intake Documentation Could not be dispositioned by LSSIR on very low safety significance status Requesting office division management authorization to move the issue up In-Depth Review Phase Acceptance Criteria TAR Safety Significance Determination (from Screening and Evaluation phase)-

clearly of elevated safety significance or indeterminate Set of well defined questions* referred from the Screening and Evaluation phase Exceptions to enter in-depth review (e.g., safety significance alone may not be the governing factor) 23 *- Questions cannot be changed in the in-depth review phase unless the process is started afresh from intake phase

Intaking Information- Highlights (Intake Phase) TAR Issue Intake Form (internal):

Fact gathering framework, collect info as early as possible from requestor Initiate discussions to accept and pre-screen issues Identify issue of concern and if it meets TAR acceptance criteria Identify unresolved questions, with underlying facts State the factual basis (provide background info, supporting documents, quotes etc.)

List questions of purely legal interpretations separately Provide licensee inputs if relevant with supporting documents if any Provide sources of other diverse facts (e.g., staff) with supporting documents, if any Provide information to support safety significance evaluation Identify/ explain if the issue is of very low safety significance and any efforts to disposition it in another routine process before seeking a TAR Requesting office BC sign off Document outcomes of Intake phase (resolved, referral to another process or route to TAR 24 Screening and Evaluation Phase) by TAR Coordinator

Screening and Evaluation Phase Results Memo Highlights TAR Screening and Evaluation Results Memo (internal):

Addressed to Requesting office division management Signature Authority: Integrated Team (IT) Chairperson Revised TAR questions (after IT deliberation) from intake form Safety Significance Determination results : (a) very low, (b) elevated or (c) indeterminate with supporting analysis Scoping and Screening results (recommend for no further regulatory action* or referrals to backfit, generic concerns or in-depth review) with supporting facts If a resolution is easily achieved, a response is recorded (e.g., issue in the licensing basis)

Description and results of licensing basis standing analysis, if relevant with supporting facts Requesting office comments TAR questions for in-depth review referrals, if applicable If exceptions exist for in-depth review, document with basis Conclusions are NRR recommendations for the issue and applicable to the specific site No agency action or decision made with this documentation 25

  • If issue is of very low safety significance and of indeterminate LB standing, it may be recommended for no further action

In-depth Review Phase Response Memo Highlights TAR In-depth Review Response Memo (internal):

Addressed to Requesting office division management Signature Authority: DORL Deputy Director Clear and concise technical review and evaluation Consideration of all inputs (include any licensee inputs received in this phase)

State TAR accepted questions and definitive answers (YES/NO) with basis and facts

  • For example: Yes. The specific requirement to define parameter X for safety-related system Y in the XYZ plant is in the licensing basis, supported by the following facts:

Governing requirements under References L, P, and Q Requesting office comments Conclusions apply for the specific issue to the specific site No agency action or decision made with this documentation 26

Next Steps Rollout and training by early December 2019 Merged NRR COM-106 completion by January 2020 27

Reference Slides 28

High safety Not clearly within the Clearly within the existing licensing basis existing licensing basis Evaluate issue to determine regulatory actions with tools such as: Address issue with appropriate tools such as:

  • 50.54(f) or generic communication
  • Enforcement
  • Backfittting
  • Order
  • If generic - screen as a generic issue
  • Consider prompt corrective actions (CAP)
  • Use LIC-504 and TIA as applicable Address issue with appropriate tools (i.e., either the Not within the licensing basis + clearly low safety - licensee comes into compliance or changes the EXIT: licensing basis):
  • Document decision
  • Corrective actions (CAP)
  • Make public record
  • Change the licensing basis (50.59, LAR, relief, exemptions, etc)
  • Assess adequacy of the requirement (i.e.,

rulemaking) 29 Low safety

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