ML20023B220
| ML20023B220 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/2020 |
| From: | Alex Garmoe NRC/NRR/DRO/IRAB |
| To: | Masters A NRC/NRR/DRO/IRAB |
| Garmoe A, 415-3814, NRR/DRO | |
| References | |
| Download: ML20023B220 (4) | |
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January 27, 2020 MEMORANDUM TO: Anthony D. Masters, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Alexander D. Garmoe, Senior Reactor Operations Engineer /RA/
Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE CROSS-CUTTING ISSUES EFFECTIVENESS REVIEW PUBLIC MEETING HELD ON JANUARY 10, 2020 On January 10, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with the Nuclear Energy Institutes (NEIs) Reactor Oversight Process (ROP) Task Force and other industry representatives. The purpose of the meeting was to hold a follow-up discussion of the staffs ongoing effectiveness review of the ROP cross-cutting issues (CCI) program and provide an opportunity for questions and comments from external stakeholders.
The initial discussion occurred as part of the ROP public meeting held on November 20, 2019 (Agencywide Documents Access and Management System (ADAMS) ML19312B550). A summary of the discussion topics is provided below.
The Director for the Division of Reactor Oversight and the Branch Chief of the Reactor Assessment Branch provided opening remarks and summarized the thorough review conducted by the team. The draft conclusions and recommendations were well-reasoned and the purpose of this meeting was to provide an opportunity for questions and feedback on the teams work, which was initially presented at the November 20 ROP public meeting (ADAMS ML19322A014).
Before providing an opportunity for questions and feedback the staff provided a recap of the information presented at the November 20 public meeting. Throughout the staffs presentation industry raised questions and provided comments about the teams work, conclusions, and recommendations. Industry comments largely consisted of the following themes: staff is lowering the bar in response to improved industry performance, this appears to be aggregating Green findings, and the staff did not properly consider available data.
As in the November 20 meeting, the staffs presentation explained much of the information and data that was reviewed by the team and how that led to proposed conclusions and recommendations. The staff reiterated that the teams review and proposed conclusions and CONTACT: Alexander D. Garmoe, NRR/DRO 301-415-3814
A. Masters 2 recommendations were also informed through extensive consideration of external and internal stakeholder feedback. The program objective is essentially to identify low level performance trends in pre-defined cross-cutting areas that could lead to more significant performance issues, and to encourage actions before such significant performance issues occur. To accomplish this objective, the program must be responsive to low level trends without being so sensitive that it is vulnerable to false positives. The number of inspection findings issued has trended downward significantly and was the subject of a separate staff study, available in ADAMS as ML19225D281. The impact on the CCI program is that the same magnitude of outlier that would have tripped a program threshold in 2015 would not trip a program threshold today. This challenges the ability of the program to identify low level trends and encourage actions ahead of significant performance issues.
The staff also discussed that the proposed CCI program changes, in particular the proposed reduction of the existing 23 cross-cutting aspects that can be assigned to a finding, do not represent an aggregation of Green findings. The program has always, from its onset, been about aggregating behavioral factors that contribute to certain inspection findings to identify trends that increase the vulnerability to the occurrence of more significant performance issues.
The complexity of the existing program, especially when combined with the reduction in data available to the program, further challenges the ability to identify developing trends ahead of significant performance issues.
One member of the public suggested the staff consider a relative threshold that would auto-adjust as the nation-wide inspection findings environment shifts. The staff noted that this was discussed as part of the effectiveness review, and from a data analysis perspective there is merit to the concept, but the team had concerns with maintaining a reliable, predictable, and consistent program and felt that this is best served with a stable threshold.
Consistent with the intent of this meeting, the effectiveness review team will consider the feedback provided as it develops conclusions and recommendations on the cross-cutting issues program. The team will transmit its conclusions and any recommendations to NRR management, as is typically done for ROP self-assessment effectiveness reviews.
Management will review the teams report and determine whether to support moving forward with any or all of the teams proposals. At this point the team anticipates completion of the report in February, though this is dependent on the time needed to adequately consider external feedback. Staff has no current estimate on if and when any future engagement at the Commission level would occur. Follow-up discussions on the CCI effectiveness review will be included on the agendas for upcoming ROP taskforce public meetings and it is possible that additional public meetings focused specifically on the CCI process may be held.
Enclosure:
Attendance List
A. Masters 3
SUBJECT:
SUMMARY
OF THE CROSS-CUTTING ISSUES EFFECTIVENESS REVIEW PUBLIC MEETING HELD ON JANUARY 10, 2020 DISTRIBUTION:
RidsRgn1MailCenter RidsRgn2MailCenter RidsRgn3MailCenter RidsRgn4MailCenter RidsNrrOd RidsNrrDro RidsNrrDroIrab RidsNrrDroIrib RidsNrrDroIrgb RidsOpaMail RidsNrrDraAphb RidsACRS_MailCTR RidsOgcMailCenter ADAMS Accession Number: ML20023B220 *via email OFFICE NRR/DRO* NRR/DRO NAME AGarmoe AMasters DATE 1/23/20 1/27/20 OFFICIAL RECORD COPY
CROSS-CUTTING ISSUES EFFECTIVENESS REVIEW PUBLIC MEETING ATTENDANCE LIST January 10, 2020 Edwin Lyman Union of Concerned Mirela Gavrilas NRC Scientists Larry Parker STARS Alliance Chris Miller NRC Marty Murphy Xcel Alex Garmoe NRC George Gellrich Exelon Mark Franke NRC Shannon Rafferty- Exelon Eric Bowman NRC Czincila Mandy Halter Entergy Rob Krsek NRC James Polickoski TVA David Aird NRC Chris Nolan Duke Energy Russ Felts NRC David Mannai PSEG Dan Merzke NRC Justin Wearne PSEG/NEI Anthony Masters NRC James Slider NEI William Schaup NRC Tony Zimmerman Duke Energy Stephanie Morrow NRC Steve Catron NextEra Rebecca Sigmon NRC Robin Ritzman Curtiss-Wright Nick Hobbs NRC Deann Raleigh Curtiss Wright Don Helton NRC Roger Wink Ameren Joylynn Quinones NRC Rob Burg EPM Larry Nicholson Certrec Enclosure